Tree removal vs. pruning: how the utility decides
No California rule chooses between removing a tree and pruning it. General Order 95 Rule 35 says dead and diseased overhang should be removed, Public Resources Code section 4293 says felled, cut, or trimmed, and neither reaches a healthy tree growing toward the conductor. The choice is made by the utility's own procedure, and PG&E's is one page long.
The inspector is two spans out on a 12 kV tap in the Sierra foothills, in front of a valley oak that was pruned in 2023 and pruned again in 2024. It is inside the minimum distance again. There is one can of paint on the tailgate and two shapes to make with it. A dot means prune. An X means remove.
Nothing in the California code tells that inspector which shape to spray.
Four rules reach the choice and none of them makes it
Four instruments in the California stack say something about removing a tree rather than pruning it. They say four different things, and three of the four reach only the dead and the failing.
General Order 95 Rule 35 names removal once:
When a supply or communication company has actual knowledge, obtained either through normal operating practices or notification to the company, that dead, rotten or diseased trees or dead, rotten or diseased portions of otherwise healthy trees overhang or lean toward and may fall into a span of supply or communication lines, said trees or portions thereof should be removed.
That is a recommendation, carried on a should. Public Resources Code section 4293 reaches the same class of tree with a shall, and then hands the method straight back:
Dead trees, old decadent or rotten trees, trees weakened by decay or disease and trees or portions thereof that are leaning toward the line which may contact the line from the side or may fall on the line shall be felled, cut, or trimmed so as to remove such hazard.
Felled, cut, or trimmed. The statute requires the hazard gone and leaves the method open. Here is the whole of what the stack says:
Instrument | The condition it reaches | What it names as the remedy | Its verb |
GO 95 Rule 35, second paragraph | Dead, rotten or diseased trees or parts overhanging or leaning toward a span | Removal | should |
PRC 4293, trailing paragraph | Dead, decadent, rotten, decayed, diseased, or leaning toward the line | Felled, cut, or trimmed | shall |
GO 95 Rule 35, third paragraph | Vegetation straining or abrading a circuit at 750 volts or less | Reduce conductor tension, rearrange or replace the conductor, prune, or place mechanical protection | shall be corrected |
Vegetation near an applicable transmission line | Documented "vegetation control methods," none of them named | shall have documented |
The last row is the reliability standard's whole contribution to the question. R3 requires each applicable owner to "have documented maintenance strategies or procedures or processes or specifications it uses to prevent the encroachment of vegetation into the MVCD of its applicable lines."
R3.2 then requires those documents to account for "Inter-relationships between vegetation growth rates, vegetation control methods, and inspection frequency." The standard asks for a method that is written down and internally consistent with the cycle. It leaves the choice of method to the Transmission Owner. Which lines the standard applies to is settled separately.
Now walk back to the valley oak. It is green, it is structurally sound, and it is growing toward the conductor at a foot and a half a year. Every row in that table is about some other tree.
The criteria are one page of a utility procedure
They sit in the utility's own document. PG&E's is Utility Procedure TD-7102P-01, "Vegetation Management Distribution Inspection," Revision 4, published October 17, 2025 and effective November 15, 2025. The criteria are Appendix G, "Further Guidance on Removal Criteria," on page 31 of 31. It is one page, and this is all of it:
Follow these steps to determine whether to prescribe a removal rather than a trim. 1. Prescribe a removal when: a. The tree is of an R1 size-class and requires work in the current cycle. b. The tree routinely will not hold an annual cycle (i.e., biannual). c. The tree requires work every year (annually), is an R2 size-class, requires work in the current cycle, and the tree is of a reoccurring constraint (e.g., interference or encroachment permit required). d. The tree has a reoccurring Priority 1 or Priority 2 status and needs work in the current cycle. 2. Exceptions to these criteria, including R3 and above holding annual cycle, requires leadership approval on a case-by-case basis.
Four criteria and one escalation. A scope of work that says the contractor will prescribe "per utility criteria" is buying that page. Ask for the page before pricing the scope. The copy of TD-7102P-01 on PG&E's public website is Revision 2, it runs Appendices A through F, and it has no removal criteria appendix in it at all.
Three of the four criteria are about the cycle, not the tree
Read the list again with the oak in mind. Health, species and structural condition are absent from all four criteria.
Every criterion is a statement about work. Does the tree need work this cycle. Will it hold a year. Has it needed work every year. Has it carried a priority tag more than once. Criterion b is the purest of the four, and it is the one that decides most removals on a fast-growing circuit: "The tree routinely will not hold an annual cycle (i.e., biannual)."
A blue gum putting on eight feet a year on a span that owes four feet of clearance cannot be pruned into a twelve-month specification without taking the crown apart. The arithmetic that turns a growth rate into a cycle is what that criterion is testing, and it is testing it against the tree's whole future, not against this morning's tape reading.
Two of the four turn on the word reoccurring. That word points at the record. An inspector cannot see from the road that a tree has carried a Priority 2 twice, or that the last two cycles both stalled on an encroachment permit. The decision is made partly from history the inspector has to have loaded before walking the span, which is one of the reasons the system of record is the inspection rather than a place to file it afterward.
The size class the criteria turn on is not defined anywhere in the document
R1 appears in criterion a, R2 in criterion c, and R3 in the exception clause. The term "size-class" appears twice in the 31 pages of Revision 4, and both occurrences are on that page. The Definitions section runs to three pages and is precise where it chooses to be, pinning Major Woody Stem to six inches of diameter at conductor level on a tree at least ten inches DBH and at least ten years old. R1, R2, R3 and size class are absent from it.
Item 2 makes the gap worse rather than better, because it can be read two ways:
Exceptions to these criteria, including R3 and above holding annual cycle, requires leadership approval on a case-by-case basis.
Read one way, an R3 or larger tree that is holding an annual cycle is being kept rather than removed, and keeping it is the exception that needs the approval. Read the other way, removing a large tree that is successfully holding its cycle is the departure, and that is what goes up the line. The two readings produce opposite prescriptions on the same tree, and they produce them on the largest trees on the circuit, where a wrong call is most expensive in both directions.
Neither the statute nor the general order settles it, because neither one is in this conversation. The utility's vegetation program settles it. Get the size class breakpoints and the reading of item 2 in writing before the season starts, attach that writing to the work instruction the inspectors carry, and record which version each unit was built under. The alternative is a removal rate that moves with which inspector walked the circuit.
Pruning is what is left over when removal is not prescribed
The order of the test is the part most readers have backwards. Removal is evaluated first. Table 4 of Revision 4 opens the Removal row with "Review Appendix G, 'Further Guidance on Removal Criteria.' to determine whether to prescribe removal," and the Pruning row begins where that review ends:
IF removal is not prescribed, THEN PRESCRIBE pruning so that vegetation will maintain compliance for 2 to 3 Routine annual inspection cycles.
Pruning is not the default prescription with removal as the escalation. It is the residual, written after the removal test comes back clear. The prescription that follows is a duration rather than a distance, and what that duration is and what else the unit has to carry is set out separately.
The wording moved between revisions, and the move is the whole point of Appendix G:
Revision 2, effective June 20, 2023 | Revision 4, effective November 15, 2025 | |
The removal step | "Prescribe removal." | "Review Appendix G, 'Further Guidance on Removal Criteria.' to determine whether to prescribe removal." |
What triggers pruning | "If removal is not practical" | "IF removal is not prescribed" |
First pruning rung | Three annual work cycles | 2 to 3 Routine annual inspection cycles |
Last rung | Bi-Annual clearance | Bi-Annual clearance after PG&E VM Representative approval |
Not practical is a judgment about the site, made by whoever is standing in front of the tree. Not prescribed is the output of a written test that somebody above them wrote down. Between June 2023 and November 2025 the pruning prescription stopped being the fallback from an impossibility and became the fallback from a rule.
On a transmission line the ladder starts at the other end, and the two programs write opposite defaults on the same species.
A reoccurring constraint is a removal criterion
Criterion c is the one landowners find hardest to believe, and it is printed as plainly as the other three. An R2 tree, needing work every year, needing work this cycle, and "of a reoccurring constraint (e.g., interference or encroachment permit required)," is a removal.
Both examples the appendix gives are about people and paperwork. Interference is a defined term in the same procedure, and its definition includes an owner who "Wants to Hire Own Contractor (HOC) or do work themselves." What the inspector's authority actually covers, and where that definition sits inside it is its own subject. Take the same valley oak on its fourth cycle. The owner has insisted three times on bringing their own arborist. The tree standing alone satisfies nothing in Appendix G. The tree plus that history satisfies criterion c.
Read what that criterion reaches. It changes the prescription the inspector writes. The right to execute that prescription comes from somewhere else entirely. A refusal that lands on a removal is still a refusal with its own workflow and its own codes, and the unit's status changes while the prescription stands.
Sometimes the correct answer is neither
The third paragraph of Rule 35 covers a secondary conductor being chafed by a coast live oak limb in a front yard. It names four corrections, and two of them are hardware:
the condition shall be corrected by reducing conductor tension, rearranging or replacing the conductor, pruning the vegetation, or placing mechanical protection on the conductor(s).
Removal is absent from that list. Exception 1 to the same rule offers an exit from cutting altogether. It reaches conductors under 60,000 volts, where "trimming or removal is not practicable" and the conductor is separated from the tree with suitable materials or devices to avoid abrasion and grounding. On that span the rule's requirements fall away. Exception 4 protects the other end of the population.
It exempts the trunks and major limbs of mature trees that sit more than six inches out from primary distribution conductors but inside the Table 1 clearance. The risk of that determination sits with the utility, and final authority sits with the Commission. How the exceptions to Rule 35 sit against the clearance table is worked through on its own page.
A crew standing under that triplex has three prescriptions available to them before anyone reaches for a saw.
The mark is the decision, and it is a dot or an X
Table 5 of Revision 4 is where the choice becomes visible from the road:
SPRAY the paint near the base of a tree using one of the following shapes: - A dot for pruning - An X for removal
The same table sets the rest of the marking discipline. Mark above the surrounding grass and bushes and above any expected snowline. Mark on the side the tree crew will likely see first. Spray new marks over marks from previous years, leaving some of the older mark showing. Cover incorrect marks with black or brown paint.
That third instruction is worth stopping on. An X sprayed over a faded dot, with an edge of the dot still visible, is the physical record of a re-prescription: a tree pruned last cycle and prescribed for removal this one. It is also the only part of the decision that exists outside a database. What that paint is worth as evidence once the crew has been and gone belongs to the audit that reads the work afterward.
Where the inspector cannot paint or flag at all, the procedure has codes for that and requires a written location within the span instead.
A removal is not re-read on the next walk
Table 3 of Revision 4 scopes what a routine Level 1 inspection re-opens:
While performing a Level 1 Inspection, the VMI must EVALUATE vegetation points with historically prescribed work (excluding removals) and vegetation points with active prescriptions not yet worked.
Excluding removals. Once the X is on the trunk and the point is in the system, the next inspector walking that circuit does not evaluate it again. That is why a tree can stand marked for two cycles, and why the owner asking about it is getting a straight answer. The reconsideration belongs to a different program.
That program runs on its own document. Attachment 6, "Tree Removal Inventory Program," Revision 1, effective January 25, 2024, puts the re-inspection of standing removals in the hands of a TRAQ-qualified inspector and fixes the outcomes it can produce.
Where the tree is gone, the reason is "Tree has already been removed." Where the facilities are gone, it is "Line Does Not Exist." Where the tree stands and no longer threatens anything, the reason is "Reassessed by TRAQ VMI" or "NO STRIKE POTENTIAL," the prescription becomes "No Work Needed," and one photograph is uploaded:
UPLOAD a photograph of the completed Basic Tree Risk Assessment Form to the vegetation point in Field Maps. No other photos should be uploaded for the vegetation point, except the Basic Tree Assessment form.
That is the route back from an X, and it runs through a credential rather than through a second opinion. Which assessment level a re-look is, and who is qualified to sign one is the machinery it borrows. Reversing the prescription without that assessment is a De-Designation, which the procedure permits and requires a documented reason for, and every change to a unit carries one.
What a removal has to carry in the record
Table 4 spends more words on documenting a removal than on deciding it. Three instructions, and one of them is a prohibition:
Select a "Reason for Removal."
Select the reasons in the "Removal Reasons" field, drawn from Appendix A, "Overview of Tree Defects and Site Conditions."
Do not put details for locating vegetation points in the "Removal Comments" field.
Appendix A is 19 bullets long, running from "Standing dead trees and dead parts of trees" to "Narrow attachment with included bark," and the procedure introduces it as "a non-exhaustive list." A reason set the document calls non-exhaustive, feeding a field an auditor will later count by category, is a place where a program's own picklist quietly becomes the standard. Settle which values exist, and settle whether an inspector may leave the list.
The prohibition is the more operational of the three. Locating detail goes in the location fields, where a crew and a dispatcher will look for it. A removal comment that reads "third oak past the barn" is not findable by anyone but its author.
The trees where the choice is not the utility's to make
Four things can take the decision off the inspector's tablet entirely, and each has a different owner.
What stops the removal | Where it comes from | Who decides |
No lawful right to cut this tree | The easement, or its absence, and the statutory rights outside it | The utility's land department, before the crew is dispatched |
The tree is exempt from the clearance the removal was serving | 14 CCR 1257 | The regulation, read against the tree on the ground |
Agency land, or an environmental feature on the parcel | TD-7102P-01 section 7.1: constraint data into the system of record for environmental review | The environmental review, through the riparian and bird nest procedures |
Caltrans or railroad right of way | TD-7102P-01 section 7.2, routing to the encroachment permitting procedure | The permitting agency, on its own clock |
The first row is the one that decides the most acres. Rule 35 Exception 2 treats trimming and removal as one permission, disapplying the rule where a company "has made a 'good faith' effort to obtain permission to trim or remove vegetation but permission was refused or unobtainable." The exception covers both prescriptions in one phrase, so a refusal reaches an X and a dot identically.
Every lawful route to a cut, and where the emergency route stops and how wide the corridor the easement actually grants is are the two pages that decide whether the prescription can be executed at all. The exempt tree provisions under Title 14 can remove the clearance obligation that motivated the removal in the first place.
Where the procedure leaves the reader, and who closes the gap
Three things in Revision 4 will slow down somebody trying to work to it.
The cross-reference is misfiled. The only pointer to Appendix G from the body of the document, other than the correct one in Table 4, hangs off a note in Table 3 about drawing in stand-alone secondary conductors: "For more information, See Appendix G, 'Further Guidance on Removal Criteria.'" Appendix G concerns removal criteria and nothing else.
The dates disagree. Pages 30 and 31 of Revision 4, which carry Appendix F and Appendix G, print an effective date of October 17, 2025. The other 29 pages print November 15, 2025.
The attachments point at the old lettering. Attachment 6 sends the reader to "Appendix D, Tree Marking Colors." In Revision 4, tree marking colors are Appendix E, and Appendix D is the service drop notification appendix. A crew following the attachment's cross-reference lands on the wrong page of the right document.
All three are settled inside the company. A program manager settles them, in a work instruction that names the revision it is written against, and a contractor asks for that instruction before the first unit is built.
On the valley oak the answer turns out to be short. The tree is not dead, so neither GO 95 nor PRC 4293 reaches it. It held twelve months and failed at twenty-four, and the owner has agreed to the work in every cycle so far. Criterion b does not fire. Removal is not prescribed, so the prescription is a prune, written for as many cycles as the cut can carry. The inspector sprays a dot.
Common questions
Further reading
What a pre-inspection produces: The unit the prescription is written into, and the duration it is written in.
Distribution vs. transmission: The same choice on a transmission line, where the ladder starts at felling.
Was the trim type correct: What the audit after the work asks of a removal and of a prune.
Frequently asked questions
Does any California rule require a utility to remove a tree instead of pruning it?
No rule makes that choice in general terms. General Order 95 Rule 35 says that dead, rotten or diseased trees or portions of them that overhang or lean toward a span "should be removed," which is a recommendation. Public Resources Code section 4293 reaches the same class of tree with a shall and then names three methods: such trees "shall be felled, cut, or trimmed so as to remove such hazard." For a green tree growing toward a conductor, neither instrument says anything about method at all.
What are PG&E's published criteria for prescribing a removal?
Appendix G of Utility Procedure TD-7102P-01, Revision 4, effective November 15, 2025. It directs a removal when the tree is of an R1 size-class and needs work in the current cycle, when the tree routinely will not hold an annual cycle, when an R2 tree needs work annually and carries a reoccurring constraint such as interference or an encroachment permit, or when the tree has a reoccurring Priority 1 or Priority 2 status and needs work in the current cycle. Exceptions require leadership approval case by case.
Why is a tree still marked with an X two years after it was marked?
Because the next inspector does not re-open the decision. Table 3 of TD-7102P-01 Revision 4 has the inspector evaluate vegetation points with historically prescribed work "(excluding removals)" on a routine walk. Removals are re-read under a separate document, Attachment 6, the Tree Removal Inventory Program, which assigns the re-inspection to a TRAQ-qualified inspector and requires a photograph of the completed Basic Tree Risk Assessment Form.
Can a property owner's conduct turn a prune into a removal?
It is one of the four criteria. Appendix G directs a removal where an R2 tree needs work every year, needs work in the current cycle, and "is of a reoccurring constraint (e.g., interference or encroachment permit required)." The same procedure defines Interference to include an owner who wants to hire their own contractor. What the utility may lawfully do on that parcel is a separate question from what the criteria prescribe.
Is pruning ever ruled out by the code rather than by the procedure?
The reverse happens. General Order 95 Rule 35 names four corrections for a circuit at 750 volts or less showing strain or abrasion, and removal is not one of them: reducing conductor tension, rearranging or replacing the conductor, pruning the vegetation, or placing mechanical protection on the conductors. Exception 1 to the same rule contemplates separating the conductor from the tree with suitable materials or devices where trimming or removal is not practicable.
