The utility's QC standard: what SW-0003 and its peers add to the code
California's rules set a clearance distance. A utility's own QC standard sets a second, tighter distance, and gives failing it a different name. PG&E publishes five of these documents, SW-0003, SW-0004, SW-0006, SW-0038 and SW-0045. Each says which number the auditor grades, which date the grade attaches to, and who is bound by it.
An auditor stands under a 500 kV transmission line on Friday, September 4, 2026, with a rangefinder and a reading of 12 feet to the nearest limb. Every regulatory clearance printed in the document in the auditor's hand is 10 feet or less. The reading is a finding anyway, and the thing that makes it one is a PG&E standard published on PG&E's own website.
PG&E publishes five of these documents. They decide what the auditor grades, which on some spans is a tighter number than the code's and on others is a different question entirely. This page is about that layer.
It covers what the standard adds on top of GO 95, PRC 4292 and PRC 4293, whom it binds, and how to tell whether the copy you are holding is still in force. What QA and QC each cover on a span and how a standard reaches a crew through a contract are separate subjects.
Two names for one failed span
The QA standard for PG&E transmission audits is SW-0045, "QAVM-Asset Transmission Audit of Vegetation Management Activities," publication date August 14, 2024, revision 00. Section 6 defines its finding types in if and then form. Two of them differ by one word:
Non-Compliances: IF a tree is observed within the minimum allowable distances outlined in FAC-003-4, GO 95 Rule 35, or PRC 4293, and does not exhibit any signs of contact with a transmission conductor. THEN the tree is considered a Non-Compliance finding type.
Non-Conformances: IF a tree is observed within PG&E's Minimum Clearance Distance, but if outside of a regulatory clearance, and does not exhibit any signs of contact with a transmission conductor, THEN the tree is considered a Non-Conformance finding type.
A non-compliance is the state's number broken. A non-conformance is the utility's own number broken, with the state's number still satisfied. That distinction is the layer this page is about, and Appendix B of the same document prices it. Here are the four figures it prints for a 500 kV line:
Appendix B table, as printed | 500 kV |
Table 1, GO 95 Rule 35 compliance clearance distance | 10 feet |
Table 2, PRC 4293 compliance clearance distance | 10 feet |
Table 3, NERC MVCD, 0 to 500 feet of elevation | 7.0 feet |
Table 4, PG&E clearance requirements | 15 feet |
Every regulatory figure the document prints is satisfied at 12 feet. The September 4 reading is a non-conformance all the same. It is written up, it carries an owner, and it goes into the count the utility reports. The distances the code itself sets, case by case and column by column and the MVCD and how its table is derived are their own pages. What matters here is that the number the auditor graded against came from Table 4.
Two things in that appendix are worth marking before anyone grades a span with it. The MVCD table prints figures for 60/70 kV, a class the NERC table has no row for, so those cells are PG&E's own determination rather than a lookup. The finding definitions also name FAC-003-4 by number, in a document published on August 14, 2024.
Which version of FAC-003 is enforceable, and when the prior one was retired, is a question to carry to the document owner, identified on the last page by title alone, as the Director of Quality Assurance Vegetation Management Asset.
Where the two numbers are the same number
On three of the four voltage classes in Appendix B, the utility's requirement and the PRC 4293 figure are the same number. SW-0045 says what to do when that happens:
There may be situations where Non-Conformance clearances are the same as Non-Compliance clearances. If a tree is adjacent to a conductor where the Non-Conformance and Non-Compliance clearances are the same, the finding would default to the more severe finding type (Non-Compliance)
It then lists exactly three combinations: 60/70 kV, 115 kV and 230 kV lines in State Responsibility Area or USFS Federal Responsibility Area during fire season. Reading Tables 2 and 4 together shows why the list stops at three:
Voltage | Table 2, PRC 4293 | Table 4, PG&E | Same figure |
60/70 kV | 4 feet | 4 feet | yes |
115 kV | 10 feet | 10 feet | yes |
230 kV | 10 feet | 10 feet | yes |
500 kV | 10 feet | 15 feet | no |
At 500 kV the utility's requirement sits 5 feet outside the statute's, so the two can never coincide and the tie-break never fires. On the other three rows a tree inside the number takes the regulatory label, and the internal one disappears.
The appendix is also explicit about where it stops. Its note under Table 2 reads: "Outside of declared fire season, SRA/USFS-FRA Non-Compliance thresholds default to GO 95 Rule 35 thresholds. Work with supervisor to discuss clearances for any non-USFS FRA sample clearances." Two facts fall out of one sentence.
The threshold moves with the declared fire season, and for land that is neither State Responsibility Area nor USFS Federal Responsibility Area, the document does not print a figure at all. It names the supervisor as the person who decides. An auditor who resolves that gap alone has made a judgment the standard assigned to somebody else.
The same word, the other way around, two documents over
SW-0006, the QC standard for routine electric transmission, grades the same asset class as SW-0045 and uses the same root word for a failure. Its section 9 defines the tag this way:
QC Trans Non-Compliant - Vegetation observed within PG&E's Minimum Clearance Distance (MCD) requirements for the Transmission voltage conductor.
In SW-0045, that tree is a non-conformance. In SW-0006, the same tree at the same distance is non-compliant. One utility, one vegetation program, two published documents, and the word points at the utility's number in one and the state's in the other.
A third meaning is already in circulation. GO 95 Rule 35 uses nonconformance for failing the General Order itself, and the rule's own definitions of strain, abrasion and contact decide when a secondary conductor has one. So a span described in an email as non-compliant is first a question about which document the writer was working from. Ask for the document number before arguing about the word, and grade the tree against the distance rather than the label.
Ninety days, and the crew's forecast date
Neither GO 95 nor PRC 4293 asks what a tree will do next quarter. SW-0045 has two finding types that do, and they split on the same axis as the first pair. A tree likely to grow or blow inside a regulatory distance within 90 days of observation is a "90 Days to Non-Compliance."
One likely to reach PG&E's Minimum Clearance Distance and stop there is a "90 Days to Non-Conformance." The 90 day clock runs from the auditor's observation date, not from the inspection date and not from the work date.
The document then removes the most common false positive in that category, and it does so by putting a research task on the auditor:
It is the auditor's responsibility to research forecast tree crew completion dates.
A tree does not qualify as a 90 day finding if it is compliant and sits on a project already scheduled for tree crew completion inside those 90 days. That holds at either stage, before pre-inspection or after it. In practice this means a 90 day finding is a statement about two dates: the day the auditor stood under the span, and the forecast completion date on the project that covers it.
A defensible finding carries both dates, because the exclusion is defined by the second one. Where the finding does stand, what happens to the unit and who carries the return trip is the next question.
The five documents, and which one grades your work
PG&E lists five quality documents among the vegetation management materials on its Community Wildfire Safety Program page. Three are QC standards, which re-inspect completed work in the field. Two are QA standards, which audit the program and the corrective action it produces.
Document | What it grades | Whom it names as stakeholders |
SW-0003, routine electric distribution, rev 03, May 31, 2024 | completed distribution locations in the High Fire Threat District | all QC Specialist personnel of the Quality Management teams |
SW-0004, vegetation control pole clearing, rev 04, effective July 3, 2024 | subject poles in HFTD or HFRA carrying a clear date | all QC personnel of the Quality Management teams |
SW-0006, routine electric transmission, rev 02, April 2, 2024 | completed transmission locations in the High Fire Threat District | all Quality Control Specialist personnel of the Quality Management teams |
SW-0038, post-audit corrective actions, rev 0, March 21, 2024 | the corrective action a QA audit finding produces | personnel conducting QAVM-Asset distribution compliance audits, and VM Execution partners |
SW-0045, transmission audit of VM activities, rev 00, August 14, 2024 | the transmission audit sample and its findings | the audit lead and all Compliance and Risk Consultants who perform VM transmission audits |
No line clearance contractor appears in any of those five stakeholder lists. Four of the five name quality personnel only. The exception is SW-0038, which reaches VM Execution partners because the corrective action lands on them, with a Corrective Action Program issue carrying "an automatically populated due date of 30 days from the initiation date."
The crew is bound by the contract, and the contract is the document to read for workmanship. What a QA/QC audit covers and how a finding becomes a corrective action and who audits whom each belong to their own page.
One practical consequence of the split. Ask for "the QC standard" and you may get any of five documents, filed under two different prefixes, since SW-0003 and SW-0045 print EO Quality on the title block and SW-0004, SW-0006 and SW-0038 print MID Quality. Ask by number.
A statutory phrase the field could not grade
SW-0004 covers pole clearing, and it states its two-layer test outright: the specialist reviews the pole "for conformance to the VC Standard and Procedure, and compliance with California Public Resource Code 4292 and California Code of Regulations (CCR)Title 14 section 1254."
14 CCR 1254(a) sets the ground level half of that cylinder, and it ends on six words that cannot be graded with a tape: vegetation "that will allow fire to spread." SW-0004 supplies the missing test:
Continuous Path: For the purposes of this procedure, this phrase provides clarity for language in CCR 1254(a) that states "…that will allow fire to spread." Fire is likely to spread outside of the Cylinder if there is a continuous path of fuel. Healthy lush green regrowth, sporadic newly dropped leaf litter or pinecones found between clearing cycles does not constitute a continuous path of fuel.
Pinecones scattered at the base of a subject pole in August are not a finding. A continuous path of fuel leading out of the cylinder is. That single definition is what makes the ground level criterion auditable, and it is a utility document rather than the regulation.
The second thing SW-0004 supplies is a date. Each of the three portions of the cylinder passes on the same wording: "The minimum clearance provisions of PRC 4292 were met on the VC clear date." Regrowth since the clear date leaves the pass intact, and the fail conditions say so directly, warning the specialist to "be aware of growth after work date."
Material blown in or placed by the customer after that date sits outside the grade as well. The statute is a continuing obligation. The QC grade is a finding about one day in the past, which is the same move SW-0003 makes on a distribution span when it asks whether clearance will hold to the next cycle.
Where that leaves the specialist with a judgment call, SW-0004 says so in capitals, and then defines the judgment: "QC WILL APPLY PROFESSIONAL JUDGEMENT TO DETERMINE IF THE POLE WAS COMPLETED AS THE CLEAR TYPE INDICATES AT THE TIME OF THE VC TECH CLEAR DATE." Its definitions section sets the bar for that judgment as "a well-reasoned conclusion that is based on the relevant facts and circumstances available at the time of the conclusion." The escalation is named too: discuss it with the QC supervisor or manager.
Where the standard reaches past the statute, and where it stops short
A utility QC standard moves in both directions at once, and SW-0004 shows both moves on the same pole type.
It reaches past the statute geographically. SW-0004 records that PG&E "has adopted (with exceptions) PRC § 4292 clearing requirements in High Fire-Threat Districts (HFTDs) and High Fire Risk Areas (HFRAs)," and names Local Responsibility Areas inside those districts among the additional areas that brings in.
Clearing there is called Risk Reduction work, and the document sets the baseline for it in one line: "Poles in LRAs are worked the same as poles within SRAs, with these exceptions." A pole in an LRA inside Tier 2 gets a cylinder cleared and a QC review on a commitment. Which land the statute reaches on its own, and the determination that puts it there is a separate question.
It also stops short of the statute substantively. On those same Risk Reduction poles:
The VC program will not conduct 1254(c) removals of dead, diseased or dying limbs or foliage from living sound trees for Risk Reduction Work poles. However, the VC program will conduct 1254(c) removals of dead trees in their entirety.
So the upper cylinder is graded to a narrower scope on a Risk Reduction pole than on a State Responsibility Area pole, and an auditor who grades the two the same way will open findings the program never committed to clearing. Which regime a pole sits in is a fact to establish before the grade. What PRC 4292 requires and which poles are subject poles is the statutory half of that question.
The same two-way movement shows up in the exemptions. SW-0004 lists ten pick list values under the heading "CCR Title 14 - 1255 BMP Partial Sub-Category Definitions." Eight track the area types in 14 CCR 1255(c) and one tracks the low landscaping exemption in 1255(d). Two differences are worth holding.
The pick list drops the condition 1255(c) attaches to every one of its eight areas, which is "if fire will not propagate thereon."
The tenth value, E-CalFire, is a letter: "Where a qualified CalFire employee writes an exemption letter for a portion or all of the cylinder for a given timeframe." Section 1255 has four subsections and none of them provides for a site-specific letter of that kind.
A pole carried as exempt on the E-CalFire value therefore rests on a document, not on a subsection. The letter, its author, its geographic extent and its expiry are the record. Which subsection carries a claimed pole exemption, and what artifact each one needs is worked through elsewhere.
The pass that still leaves a fire risk
Every grading scheme produces a case where the work was done correctly and the site is still wrong. Most standards leave it to the auditor's conscience. SW-0004 gives it a channel, a recipient and an interval:
If the VC Scope of work has been met, but a condition exists where a fire can spread outside of the cylinder. Then provide location details to QC supervisor. These pole locations will be collected and submitted by email to the local VC execution lead and QAP Supervisor on a weekly basis during declared fire season (summer preparedness).
The pole passes. The pass is recorded. The location travels anyway, by email, once a week, and only while fire season is declared. For an auditor that is the whole answer to "it met scope and I do not like it": it is a Tuesday observation that appears on that week's email, and it is not a finding against the crew.
SW-0045 carries the opposite case, where the condition is too serious for any list. On a tree/line contact or a non-compliance finding, "auditor is to immediately notify the local transmission VPM and remain onsite to secure scene until relieved by VM Execution."
The auditor may leave only if the site is unsafe or if moving is needed to get cell service, or with the vegetation program manager's permission. A QA standard has made standing under a span part of the audit. Who may accept a span, and where stop-work authority sits is the related question on the other side of the finding.
Which revision governs your span
The five documents split on how they stay in force, and the difference decides what a downloaded copy is worth.
Document | How it stays in force, as printed |
SW-0003 | editorial or requirement test only |
SW-0004 | editorial or requirement test only |
SW-0006 | annual review and approval, plus the editorial or requirement test |
SW-0038 | annual review and approval |
SW-0045 | annual review and approval |
The three that carry the annual clause print the same requirement, with SW-0045 spelling out the month: "To remain active document must be reviewed and approved annually within 1 month of anniversary of previous approval." The editorial test, in the two others, reads that any update which does not change requirements "does not require reapproval," while a change to requirements "requires the document to be reapproved." Approval comes from QC leadership.
Read together, those two mechanisms make a revision number weak evidence on its own. An editorial revision skips reapproval, so a bumped number proves only that something changed. An annual reapproval can happen silently, so an unmoved number leaves the question open.
The published copy of SW-0045 carries one entry in its revision notes, revision 00 dated August 14, 2024, and the published copy of SW-0038 carries one, revision 0 dated March 21, 2024. Each has passed two anniversaries of the date printed on it. Neither copy can tell you whether the review happened.
What does carry information is the description column. Revision 02 of SW-0004, dated February 26, 2024, reads: "Remove ANSI finding question, remove timing requirement, text, and formatting revisions, clarified only review subject poles in HFTD/HFRA." A question that had been on the pole clearing survey came off it that day.
An auditor working to revision 04 will look for it in vain, and a 2023 audit file carrying an ANSI grade on a subject pole is correct as filed. What an ANSI grade on a span carries is its own page, and SW-0003's amendment history and the two tag definitions it left identical are read out in detail elsewhere.
One smaller trap. SW-0006 prints its publication date twice and the two differ: 04/02/2024 in the title block, 04/04/2024 in the page footer, both at revision 02. Cite the document by revision as well as by date, and the two day gap stays a typographic curiosity.
Where the published set runs out
The five published documents are mostly pointers. SW-0003 sends the reader to Appendix A of the distribution inspection procedure, TD-7102P-01, for the minimum distance numbers, SW-0004 names the vegetation control standard and procedure and several job aids, and SW-0045 names the transmission program standard and inspection procedure. Some of those targets are published beside them. Several are absent.
SW-0004 sends the specialist to job aid TD-7112P-01-JA05 for pictures of all subject equipment. That job aid is absent from the Community Wildfire Safety Program list.
SW-0045 tells auditors to follow "guidelines in published version of the QAVM-Asset Sample Omission Standard Work Document." That document is absent from the list as well.
SW-0003's safety reference is Utility Standard SAFE-1039S, Lone Workers, which is also absent.
SW-0003's secondary conductor criterion, at section 3.4, cites "TD-7120P-01: Vegetation Management Distribution Inspection Procedure." Every other reference in the document, and the summary on its first page, gives that procedure as TD-7102P-01. Two digits are transposed, and a search on the printed number returns nothing.
So a reader working only from the public set can read the question while the reference that answers it stays out of reach. Where the chain breaks, the contract has to supply the document, by number and by revision, and that is a procurement task rather than a research task.
Outside PG&E, the public set is usually empty. PacifiCorp's arrangement is visible mainly through California Energy Safety's Independent Evaluator, which recorded a "Forester signing off work as it is complete" and noted that PacifiCorp "reviews pre-inspections (prescriptions) at the time of conducting audits of completed work."
The evaluator's own remit includes verifying a utility's "control (QA/QC) programs," whatever documentation stands behind them. A utility that keeps its standard internal still has one, in its contract and its work management system, and the audit interval it commits to in its wildfire mitigation plan is graded the same way.
What the standard has to name
Before working to a utility QC standard, or auditing against one, pull five things off its face page and its last page.
The number, the revision and the date, all three, because one of the five prints two different publication dates under one revision.
The scope clause, which decides what gets skipped rather than graded. SW-0003 reaches distribution routine locations in the High Fire Threat District, so a clean pass rate speaks only to spans inside it.
The reference chain, and which of its links you can actually open.
Which word the document uses for the internal failure, and which for the regulatory one, since SW-0006 and SW-0045 use "non-compliant" for different distances.
How it stays in force, and who approves it. QC leadership, in the three QC standards, and in all five a document owner identified by job title with the name stripped out of the published copy.
For a finding, the same discipline produces four facts: the distance measured, the table it was graded against, the date of the observation, and the finding type the document defines for that combination. What the closed unit has to hold afterward and what the utility receives at the end of a cycle start from that record.
Further reading
What a QA/QC audit actually covers in utility vegetation work: The unit under audit, the defect classes, and the corrective action a finding becomes.
ANSI standards met: A300 in the audit: The other document that reaches a span, and the edition question a contract clause settles.
Trim type correct: the audit against the prescription, cut by cut: SW-0003 read line by line on one work order, including its own amendment history.
Frequently asked questions
What does a utility QC standard add that GO 95 and the Public Resources Code do not already require?
A second clearance number, a name for breaking it, and a date the grade attaches to. PG&E's SW-0045 defines a non-compliance as a tree inside the distances in FAC-003-4, GO 95 Rule 35 or PRC 4293, and a non-conformance as a tree inside PG&E's own Minimum Clearance Distance but outside the regulatory one. Its Appendix B sets that internal distance at 15 feet for a 500 kV line, against 10 feet in its GO 95 and PRC 4293 tables.
Does non-compliant mean the same thing in every PG&E QC document?
No. In SW-0045, a QA transmission audit standard, Non-Compliance is the regulatory breach. In SW-0006, the QC standard for routine transmission, the tag QC Trans Non-Compliant is defined as vegetation observed within PG&E's own Minimum Clearance Distance. GO 95 Rule 35 uses nonconformance for failing the rule itself. Read the document that governs the team standing in front of you before reading the word.
Where can a contractor read the QC criteria its work will be graded against?
PG&E publishes five quality documents on its Community Wildfire Safety Program page: SW-0003 for routine distribution, SW-0004 for vegetation control pole clearing, SW-0006 for routine transmission, SW-0038 for post-audit corrective actions and SW-0045 for the transmission audit. Most utilities publish none, in which case the standard arrives through the contract and has to be requested by document number and revision.
How do you tell whether a published utility standard is still in force?
By its revision clause, and then by asking. SW-0006, SW-0038 and SW-0045 each state that to remain active the document must be reviewed and approved annually within one month of the anniversary of previous approval. SW-0038 and SW-0045 carry only their original publication revisions, dated March 21, 2024 and August 14, 2024. A downloaded copy cannot show a review that produced no revision note.
Do these standards bind the tree crew?
Not directly. All five name only quality personnel and, in SW-0038, VM Execution partners as stakeholders. No line clearance contractor appears in any of the five stakeholder lists. The crew is reached by the contract that names the utility's specification, which is where an auditor grading workmanship has to look.
