What a pre-inspection produces: the work order before the crew
A pre-inspection produces a unit of work: a vegetation point located well enough to find, a prescription written as the number of inspection cycles it must hold, every contact attempt with the owner, the constraints that will stop the crew, and a documented reason for each later change. Those fields come from the utility's own procedure.
An inspector is standing in a driveway on a distribution circuit. There is a tree that needs work, and a customer refusing to have paint put on it. PG&E's procedure has an answer, and the answer says more about this subject than any definition of pre-inspection would:
IF the VMI cannot paint or flag a tree, THEN UPDATE the tree record with the code "CNP" (cannot paint) or "CNF" (cannot flag) AND INCLUDE a description of the tree's location within the span.
The mark on the trunk is a convenience. What the crew is actually dispatched against is a record, and that record has to be good enough to find a tree the inspector was forbidden to mark. Everything a pre-inspection produces is measured against that standard.
The document those instructions come from is Utility Procedure TD-7102P-01, "Vegetation Management Distribution Inspection," Revision 4, published October 17, 2025 and effective November 15, 2025. It was filed as an attachment to PG&E's 2026 to 2028 Base Wildfire Mitigation Plan, which is why a contractor, a prime or an evaluator can read it. One utility's procedure binds that utility alone. It is also a working example of what the output of a vegetation pre-inspection looks like once somebody has had to write it down.
The unit is what a crew can work without a phone call
A pre-inspection produces vegetation points. A point is a tree, or a group of stems, tied to a location on a circuit and carrying a prescription. Section 4.2 of the procedure is one line, and it is the handoff: "DOCUMENT the prescribed work into the system of record."
The record has to answer two questions before a crew leaves the yard. Which tree, and what is being done to it. The CNP and CNF codes exist because the first question has a failure mode that belongs to property access rather than arboriculture. A property owner who blocks the paint, or a bank too steep to walk, leaves the crew with a span and a bare trunk. The procedure's response shifts the burden into text: describe where in the span the tree stands.
The same discipline runs through the removal fields. An inspector prescribing removal selects a Reason for Removal and populates a Removal Reasons field. The procedure then says something that only makes sense once you have seen a crew work from a screen: "Do NOT provide details for locating vegetation points in the 'Removal Comments' field."
Locating information has its own place in the record. A comments box that collects it becomes the only place anyone looks, and a unit with a blank comment then turns into a search. Where the vegetation point lives after the tablet closes is its own subject, and it is the reason field discipline matters at all.
The prescription is a duration, not a distance
Reading the prescription as a clearance figure is the common mistake, and it is worth correcting before anything else on the page.
The clearance a crew has to achieve is set by rule. General Order 95 Rule 35 and its Table 1 set one set of numbers, Public Resources Code section 4293 sets another, and an applicable transmission line answers to the MVCD. The inspector writes something else into the prescription. The inspector writes how long the cut has to last.
Table 3 of the procedure puts the inspector's test in the future tense:
Vegetation has or may encroach the MDR, based on anticipated growth rates before the next Routine annual inspection cycle.
Table 4 then converts that prediction into a prescription, in a ladder with three rungs:
IF removal is not prescribed, THEN PRESCRIBE pruning so that vegetation will maintain compliance for 2 to 3 Routine annual inspection cycles.
Where two to three cycles is beyond reach, the inspector prescribes to hold for one. Where one cycle is beyond reach, the prescription drops to Bi-Annual clearance, and only after a PG&E VM Representative approves it. That approval is the interesting part. The bottom rung belongs to the VM Representative, so the pre-inspection on that tree produces a request rather than a prescription.
The rung the inspector lands on changes the cut. It is worth knowing that the rung moved. Revision 2 of the same procedure took effect June 20, 2023, and it was still the copy on PG&E's public website in September 2026. Its top pruning rung read "prescribe pruning such that the tree will maintain compliance for three annual work cycles," and it left the bottom rung with the inspector.
How growth rate and cycle length set that number and what a clearance at time of trim has to be for it to still be a clearance later are the two inputs the inspector is really weighing. The audit that grades the finished cut against the prescription comes afterward and is somebody else's job.
The notification record travels with the unit
Contact with the property owner is an output of the pre-inspection, and the procedure specifies it as fields rather than as an activity. Section 6.1 requires the inspector to attempt contact directly, describe the work, and then document the attempt with at least four details:
Method of contact
Name of customer or property owner who was contacted
Date and time that contact occurred
Outcome of the contact attempt
An unanswered door at 8:40 on a Tuesday is an outcome, and it is a row in the record. Where the first attempt draws silence, the procedure requires up to two more, with the details and method of each entered into the system. An Americans with Disabilities Act concern raised by the owner is captured as an ADA alert flag on the record rather than as a note.
Four fields and three attempts is a small thing until somebody asks, two years later, whether an owner was told. At that point the pre-inspection file answers, or the utility is left reconstructing. What notice a utility owes and what a refusal actually entitles it to do is a separate question of law, and the workflow a refusal triggers starts where this record ends.
Constraints are found by the inspector or they are found by the crew
The procedure defines a constraint narrowly, and the definition is worth reading because it names what the pre-inspection is protecting the crew from:
Constraint: A situation that occurs when an environmental concern or local government or agency obstructs or delays PG&E inspection work or the completion of intended tree work.
Section 7.1 makes it an output. Where work is prescribed on agency land, or where the site carries an environmental feature such as a bird nest, a riparian area, a cultural resource or Valley Elderberry Longhorn Beetle habitat, the inspector adds constraint data into the system of record for environmental review. Work inside a Caltrans or railroad right of way routes to the encroachment permitting procedure instead. In both cases the pre-inspection is buying lead time, which is the one thing a crew standing at the pole has already spent.
That is the whole economic argument for pre-inspection, and it is visible in the wording. A permit found in October is a scheduling problem. The same permit found by a three-person crew and a bucket truck at the pole is a truck roll. Nesting seasons and the windows they close work the same way, and they close on calendar dates the inspector can see months ahead.
On an applicable transmission line the federal standard reaches the same object from the other end. NERC Reliability Standard FAC-003-5 Requirement R5 fires when an entity is constrained from performing vegetation work and the constraint may lead to an encroachment before the next annual work plan. Measure M5 lists what the entity is expected to be able to produce:
Examples of acceptable forms of evidence may include initially-planned work orders, documentation of constraints from landowners, court orders, inspection records of increased monitoring, documentation of the de-rating of lines, revised work orders, invoices, or evidence that the line was de-energized.
The initially-planned work order is the pre-inspection's product, and the revised work order is what the constraint did to it. A program that wrote the first one has something to revise and something to hand an auditor. How the seven requirements of FAC-003-5 fit together is the wider frame; the point here is narrow. The standard names the artifact.
What falls outside the scope still produces a record
The clearest way to see what a pre-inspection produces is to look at what the inspector is excused from inspecting.
Table 3 says plainly that PG&E is not required to inspect vegetation on service drops. It then adds a condition that survives the exclusion. An inspector with actual knowledge of strain, abrasion or hazard tree risk on a service drop goes to Appendix D, which walks through filing a notification in the Report It application, and specifies the comment string to be typed into the description field:
Confirmed strain and abrasion on service drop. Please create a 540 notification.
A fixed string, because a 540 notification is created by somebody else reading that field. Idle lines get the opposite treatment: they are inspected as if they are energized, whether or not they currently serve load.
Scope decides what the inspector looks for. What the inspector does with what they see is decided elsewhere. That gap is the difference between a program that finds problems and one that also records them, and it is why a pre-inspection file carries units on facilities outside the inspection cycle.
Every change to a unit carries a reason
A prescription becomes final when the work is closed out. Between the inspector's entry and that moment it can move.
The procedure gives the two moves names. De-Designation is any change of a vegetation point from Removal to a different prescription. De-Listing is any change of a tree prescription to No Work. Both carry the same obligation:
When De-Designating a vegetation point from a removal to any other prescription type OR De-Listing a vegetation point, the VMI must DOCUMENT the reason in the system of record.
The reason is the product here, more than the change. A removal that became a trim tells an auditor little on its own. A removal that became a trim because the owner produced a permit, or because a second look put the tree outside the fall zone, is a defensible decision with a date on it.
Transmission handles the same event at plan level. FAC-003-5 R7 permits work plan modifications in response to changing conditions or to inspection findings, provided they do not allow an MVCD encroachment, and requires that they "must be documented." Completion is then measured against the amended plan rather than the original, which puts the amendment record directly into the compliance percentage. Which lines that plan has to cover, and the arithmetic the percentage uses are set out separately.
No regulation says what a prescription must contain
Somebody writing a scope of work or grading a bid will want a citation for the required fields. That citation is missing from the code, and saying so beats inventing one.
FAC-003-5 is explicit about it. Its supplemental material, discussing R7, says the annual work plan requirement "is not intended to necessarily require a 'span-by-span', or even a 'line-by-line' detailed description of all work to be performed." What the standard wants is evidence of annual planning and execution. The evidence list it offers is deliberately broad: signed-off work orders, signed contracts, printouts from work management systems, spreadsheets of planned versus completed work, timesheets, work inspection reports, or paid invoices. Any of those can satisfy R7. The standard leaves the choice open.
The state side is aimed elsewhere. General Order 165 sets a content standard for a distribution inspection record, and what separates a patrol from a detailed inspection under it is a question about facilities rather than tree work. General Order 95 and the Public Resources Code set clearances, and both stop there.
So the answer to "what must a pre-inspection produce" is the utility's own procedure, and behind it the contract that names the procedure. PG&E's Revision 4 makes its own chain visible, listing as its compliance requirements General Order 95 Rules 33.1, 35, Rule 35 in Appendix E and Rule 18, Public Resources Code sections 4293 and 4295.5, and Title 14 section 1257. The procedure is the bridge between those rules and a field tablet.
Which means the live question for a prime is a version question, and it is checkable. As of September 20, 2026, the TD-7102P-01 posted on PG&E's public website carried Revision 2, published April 20, 2023.
The copy filed with Energy Safety in the 2026 to 2028 Base WMP docket carried Revision 4, effective November 15, 2025, and its rescission list retires Revision 3 of April 28, 2025. Two revisions separate those documents, and one of the things that changed between them is the pruning ladder every prescription on the system is written against.
A field guide, a training deck or a subcontractor flow-down that still quotes "three annual work cycles" is quoting a rescinded revision. Nobody sends a notice when that happens. The inspector standing in the driveway is working to whichever version reached them.
Common questions
Further reading
The system of record: Where the vegetation point lives after the inspector closes the tablet.
Field hazard tree assessment: The Level 2 look that sits behind a strike tree prescription.
Tree removal vs pruning: how the utility decides: Which prescription the inspector writes, and on what grounds.
Frequently asked questions
Is a prescription a clearance distance?
It is a duration. Rev 4 of PG&E's procedure, effective November 15, 2025, directs the inspector to prescribe pruning so vegetation "will maintain compliance for 2 to 3 Routine annual inspection cycles," dropping to one cycle where that is beyond reach, and to Bi-Annual clearance only after a PG&E VM Representative approves. The distance is set by the clearance rules. The number of cycles the cut has to survive is what the inspector writes down.
Does any regulation say what fields a work prescription must contain?
No. NERC FAC-003-5 says the opposite in its supplemental material: the annual work plan requirement "is not intended to necessarily require a 'span-by-span', or even a 'line-by-line' detailed description of all work to be performed." CPUC General Order 165 sets a content standard for a distribution inspection record, and stops there. The fields come from the utility procedure and the contract that names it.
Who decides which revision of the utility procedure a prime is working to?
The utility, by issuing it. This is checkable and it moves. As of September 20, 2026 the copy of TD-7102P-01 on PG&E's public website carried Revision 2, published April 20, 2023. The copy attached to the 2026 to 2028 Base Wildfire Mitigation Plan filing at Energy Safety carried Revision 4, effective November 15, 2025, and its rescission list retires Revision 3 of April 28, 2025. A field guide quoting the three-cycle language from Rev 2 is quoting a rescinded document.
What happens to a unit the crew cannot work as prescribed?
On distribution it becomes a De-Designation or a De-Listing, and the procedure requires the inspector to document the reason in the system of record. On an applicable transmission line the same event is a work plan modification under FAC-003-5 R7, which permits changes in response to changing conditions or inspection findings and states that they "must be documented." The percent completed is then measured against the amended plan, which is why the amendment record matters as much as the original.
Does a pre-inspection produce anything for facilities outside its scope?
Yes. PG&E is not required to inspect vegetation on service drops, but an inspector with actual knowledge of strain, abrasion or hazard tree risk on one follows Appendix D and files a Report It notification with a fixed comment string: "Confirmed strain and abrasion on service drop. Please create a 540 notification." Idle lines are inspected as if they are energized. Out of scope still leaves a record.
