ELECTRIC LINE CLEARANCE MANAGEMENT PLAN 2017/18 · 2017-10-05 · electric line clearance management plan 2017/18 document number: ue pl 0010 version 5.0 – september 2017 page 2

ELECTRIC LINE CLEARANCE MANAGEMENT PLAN 2017/18

Electric Line Clearance Management Plan 2017/18 (Version 5.0 – September 2017)

United Energy Pinewood Corporate Centre Level 3, 43-45 Centreway Place Mt Waverley VIC 3149

Document № UE PL 0010


Document Number: UE PL 0010

Version 5.0 – September 2017

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UNCONTROLLED WHEN PRINTED

LIABILITY DISCLAIMER

This Electric Line Clearance Management Plan (‘the Plan’) has been prepared to inform relevant stakeholders of the asset management approach, processes and strategies applied to United Energy (UE). This Plan has also been prepared for the purposes of the Electricity Safety (Electric Line Clearance) Regulations 2015 (Vic).

Some of the information and statements contained in the Plan are comprised of, or are based on, assumptions, estimates, forecasts, predictions and projections made during UE’s annual Asset Management planning cycle. In addition, some of the information and statements in the Plan are based on actions that UE currently intends it will take in the future. Circumstances will change, assumptions and estimates may prove to be wrong, events may not occur as forecasted, predicted or projected, and UE may, at a later date, decide to take different actions to those it currently intends to take.

Except for any statutory liability which cannot be excluded, UE will not be liable, whether in contract, tort (including negligence), equity or otherwise, to compensate or indemnify any person for any loss, injury or damage arising directly or indirectly from any person using, or relying on any content of, the Plan.

When considering any part of the Plan, persons should take appropriate expert advice in relation to their own circumstances and must rely solely on their own judgement end expert advice obtained.

September 2017




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TABLE OF CONTENTS

1 PURPOSE 5

2 VISION, STRATEGY AND FOCUS AREAS 5

3 FIRE PREVENTION POLICY 6

4 VEGETATION MANAGEMENT FRAMEWORK 7

5 VEGETATION MANAGEMENT OBJECTIVES AND STRATEGIES 7

6 PLAN PREPARATION AND INFORMATION 8

7 COMPLIANCE WITH THE REGULATIONS 8

8 SERVICE AREA CHARACTERISTICS 8

9 UE GEOGRAPHIC AREA 10

10 UE VEGETATION MANAGEMENT ZONES 12

11 STRUCTURE, ROLES AND RESPONSIBILITIES 13

11.1 UNITED ENERGY MANAGEMENT / SERVICE PROVIDER STRUCTURE 13

11.2 ELCMP ROLES AND RESPONSIBILITIES 14

11.3 RESPONSIBLE PERSONS – CONTACT DETAILS 16

11.4 APPOINTMENT OF SERVICE PROVIDERS 17

11.5 GENERAL REQUIREMENTS 17

11.6 SPECIFIC REQUIREMENTS 17

12 DEFINITIONS 18

13 ATTACHMENTS 18

14 REFERENCES 18

15 MANAGEMENT PROCEDURES 19

15.1 SELECTION OF THE METHOD FOR MAINTAINING CLEARANCES 19 15.1.1 Calculating Applicable Distance (Spans <100m) 20 15.1.2 Calculating Applicable Distance (Spans >100m) 20

15.2 MAINTENANCE OF THE VEGETATION CLEARANCE SPACE 20 15.2.1 Procedure 21 15.2.2 Regrowth Space 21 15.2.3 Hazard Trees 21 15.2.4 Planned Cutting in the Hazardous Bushfire Risk Area 22 15.2.5 Urgent Cutting or Removal Works 22

15.3 VEGETATION CODE DEFINITIONS AND ACTIONS 23 15.3.1 United Energy HBRA Vegetation Management Codes 23 15.3.2 United Energy LBRA Vegetation Management Codes 24 15.3.3 United Energy Cutting Schedules 2017/18 25

15.4 RESPONSIBLE CUTTING PRACTICES 26 15.4.1 Adherence to AS 4373 26 15.4.2 Procedures – including Training, Qualifications and Experience 26 15.4.3 Herbicide Use 27

15.5 ALTERNATIVE TREE MANAGEMENT PROPOSALS 27 15.5.1 Alternate Compliance mechanisms 27 15.5.2 Long Term Strategies 28




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15.6 IMPORTANT TREES 28 15.6.1 Species Identification 30 15.6.2 Trees of Significance Listed in a Planning Scheme 30 15.6.3 Trees that are Culturally or Environmentally Significant 30 15.6.4 Victorian Heritage Register. 30 15.6.5 Victoria Aboriginal Heritage Register. 30 15.6.6 Habitat Trees for Threatened Fauna 30

16 NOTIFICATION, CONSULTATION AND NEGOTIATION 31

16.1 NOTIFICATION FOR CUTTING OR REMOVAL 31 16.1.1 Published Notices 32 16.1.2 Consultation for Cutting or Removal 32 16.1.3 Negotiation Process 33 16.1.4 Dispute Resolution Procedure 34 16.1.5 Customer Complaint Process 35

17 MONITORING, REPORTING AND AUDITING 35

17.1 AUDITING 36 17.1.1 Audit Roles and Responsibilities 36 17.1.2 Schedule and Frequency 36 17.1.3 Recording and Managing Results 37 17.1.4 Summer Inspection Programs in HBRA 38 17.1.5 Compliance with the Code 38 17.1.6 Exception to minimum clearance space 38

18 ASSISTANCE TO COUNCILS AND LAND OWNERS/OCCUPIERS 38

18.1 INTERACTION WITH COUNCIL AND LAND OWNERS/OCCUPIERS 39 18.1.1 Declared Area Hazard Tree Rectification Process 39 18.1.2 Non Compliance by Councils or Other Responsible Persons (ORP) 39 18.1.3 Management of vegetation that is Council Responsibility (Flowchart) 39 18.1.4 Service Lines 40

19 ATTACHMENTS 41

19.1 ATTACHMENT A.1. - CUSTOMER NOTIFICATION LETTER (SAMPLE) 41

19.2 ATTACHMENT A.2. - CUSTOMER NOTIFICATION LETTER - CUTTING PRACTICES (SAMPLE) 43

19.3 ATTACHMENT A.3. - CUSTOMER NOTIFICATION LETTER – CONTIGUOUS LAND (SAMPLE) 44

19.4 ATTACHMENT A.4. - CUSTOMER NOTIFICATION LETTER – URGENT CUTTING (SAMPLE) 45

19.5 ATTACHMENT A.5. - CUSTOMER NOTIFICATION LETTER – IMPORTANT TREES (SAMPLE) 46

19.6 ATTACHMENT A.6. - CUSTOMER NOTIFICATION LETTER–SERVICE LINES (SAMPLE) 47

19.7 ATTACHMENT A.7 – CURRENT UE BROCHURES AND ADVERTISEMENTS 48

19.8 ATTACHMENT A.8 – EXAMPLE - NEWSPAPER ADVERTISEMENT: 50

19.9 ATTACHMENT A.9 – EXAMPLE – ESV LETTER SUPPORTING COMPLIANCE 50

19.10 ATTACHMENT B.1 – COPY OF SCHEDULE 2 CODE OF PRACTICE FOR ELECTRIC LINE CLEARANCE

51

19.11 ATTACHMENT B.2 – UNITED ENERGY APPLICABLE DISTANCE CHARTS 54




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APPROVAL AND AMENDMENT RECORD

Issue: 4.0

Operative Date: 1st July 2017


VERSION DATE UPDATED BY

1.0 March 2016 Trevor Fisher

2.0 June 2016 Trevor Fisher

3.0 October 2016 Trevor Fisher

4.0 March 2017 Trevor Fisher

5.0 September 2017 Trevor Fisher

POSITION

NAME

Prepared by Fire Prevention Manager

Trevor Fisher

Reviewed by Vegetation Manager

Wayne Evans

Reviewed by Network Risk, Safety and Technical Compliance Manager

Mike Tshaikiwsky

Approved by General Manager Networks, Electricity

Mark Clarke

Approved by General Manager, Service Delivery

Ross Musgrove

Notes / Changes

ITEM

SECTION

PAGE

AMENDMENT

1. Throughout Document

Various Update from Version 4.0 March 2017 to Version 5.0 August 2017


Various General Minor Amendments, title changes etc….

3. 15.3.1 and 15.3.2 26 and 27 Update to United Energy HBRA and LBRA Vegetation Management Codes


Various As recommended by ESV assessments of plan




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1 Purpose

The purpose of the UE Electric Line Clearance Management Plan (ELCMP) is to detail the operating systems and management practices implemented by UE to manage the vegetation clearance space around overhead powerlines. The ELCMP demonstrates electricity network safety due diligence to a level that is as low as reasonably practicable (ALARP) in managing the risks:

to the safety of the public, staff and customers,

of property damage, and

due to supply interruption.

2 Vision, Strategy and Focus Areas

This section provides a brief overview of our vision, objectives and values in facing the challenges ahead.

The corporate roadmap outlines United Energy’s vision, focus areas and key objectives. The roadmaps build on our strategy with new objectives, initiatives and a strategic focus of a Winning Culture.

Our purpose is to provide our customers with a safe, reliable and sustainable energy supply.

Our vision is to create the Intelligent Utility to deliver a more sustainable way of meeting the energy needs of our customers, now and into the future. We will achieve this by focusing on industry leadership and innovation and working in the best interests of all of our stakeholders.

Our values guide us in everything we do: safety, accountability, collaboration, communication, winning culture, empowerment and respect

We are thinking about what our customers will want from “energy” in five, 10, 20 and 50 years. As the Intelligent Utility, we will give our customers access to the best technology and an advanced network, with a priority on efficiency and on building our reputation by meeting their current and future requirements.

Five key focus areas will drive departmental business plans and our key performance indicators (KPIs).

Strong financial management o Set up our business to maximise shareholder distributions and deliver the greatest value possible.

Innovation and continuous improvement o We are innovating to drive greater value out of our business to prioritise safety, efficiency and reliability of service.

Customer Focus o We are developing a customer-focused operating model to deliver an effortless experience for our customers.

Future Focus o We are responding to our changing environment with a focus on industry leadership, emerging technologies, and new

growth opportunities.

Winning Culture o We will build a unique, winning culture that is set apart by the capability of its leaders and employees, the standards of

behavior and performance it lives by, and its drive for innovation, continuous improvement and results.




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3 Fire Prevention Policy

UE’s vegetation management principles, strategies and objectives are supported by the UE Fire Prevention Policy and Fire Prevention Plan which aim to maintain a high level of public safety and supply reliability through appropriate preventative and corrective maintenance programs, designed to minimise the risk of fire ignition due to the vegetation near overhead powerlines.




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4 Vegetation Management Framework

The purpose of the section is demonstrate, to shareholders, customers, staff, service providers, the community and stakeholders UE’s commitment to delivering value through the application of an effective vegetation management framework.

UE is committed to delivering shareholder value through the application of an effective vegetation management framework that ensures a safe, reliable, and compliant supply of electricity to our customers.

Vegetation management activities will meet business objectives and benefit customers, stakeholders, and staff by:

meeting the requirements of the Electricity Safety (Electric Line Clearance) Regulations 2015

implementing vegetation management programs designed to prevent harm and minimise outages, damage and the risk of fire ignition caused by vegetation near overhead powerlines

building a reputation as a trusted, leader in customer service

adopting industry practice, in environmentally responsible vegetation management

a commitment to work place safety, by managing reasonably foreseeable and credible safety risks

embedding continuous improvement and innovation to drive efficiency.

5 Vegetation Management Objectives and Strategies

The purpose of this section is detail the vegetation management principles, strategies and objectives developed by UE to deliver an effective vegetation management framework that ensures a safe, reliable, compliant, and cost-effective supply of electricity to our customers.

To maintain supply reliability and mitigate the risks to staff, service providers, customers, the community and the environment caused by the interaction of trees and powerlines, UE will prepare an ELCMP that meets the requirements of UE’s corporate objectives, the Regulations and the Code of Practice for Electric Line Clearance.

This will ensure that the vegetation clearance space is maintained in accordance with the Electricity Safety (Electric Line Clearance) Regulations 2015 and that vegetation around the vegetation clearance space is managed using current industry practice.

The performance of the plan will be monitored on a monthly basis using the Key Performance Indicators specified in section 4 of Energy Safe Victoria “Electrical Infrastructure Safety Electrical Incident and Safety Performance Reporting Guidelines”.

The vegetation management principle is supported by objectives and strategies:

Vegetation Management Framework Principle

Vegetation Management Strategy

Vegetation Management Objective

Meet the requirements of the Electricity Safety (Electric Line Clearance) Regulations 2015

Implement vegetation management programs designed to prevent harm and minimise outages, damage and the risk of fire ignition caused by vegetation near overhead powerlines

Prepare an ELCMP that complies with the requirements Electricity Safety (Electric Line Clearance) Regulations 2015

Monitor, and report (audit) on the implementation of the approved ELCMP

Monitor, and report (audit) on the vegetation performance of the network

ELCMP approved by ESV

UE governance system (GRC) confirms Regulatory compliance

Monitoring, auditing and reporting confirms operational compliance with Regulations and the approved ELCMP

Vegetation performance:

no bushfires in the region,

no ground fires in Hazardous Bushfire Risk Areas (HBRA), on TFB/code red days

no harm to persons

minimise the damage to assets

minimise vegetation outages

Build a reputation as a trusted, leader in customer service

Adopt industry, practice, in environmentally responsible vegetation management

Embed continuous improvement and innovation to drive efficiency

Notification, consultation, and negotiation with customers on vegetation management programs

Notification, consultation, and negotiation with councils on vegetation management programs

Minimise the number of customer complaints regarding vegetation management

Minimise the number of vegetation non-compliances




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Vegetation Management Framework Principle

Vegetation Management Strategy

Vegetation Management Objective

Commit to work place safety, by managing reasonably foreseeable and credible safety risks

Identify the risks and implement controls to reduce risks to ALARP

No harm to staff, customers, the public, service providers or council workers.

6 Plan Preparation and Information

It is acknowledged by UE that under regulation 10(1) and 10(2) it must prepare a management plan and submit it for

approval to Energy Safe Victoria (ESV) on or before 31 March each year and must:

Under regulation 10(3) - provide a copy of the management plan to ESV on request within 14 days or such longer period as specified by ESV

Under regulation 10(4) - provide further information in respect of the management plan on request within 14 days or such longer period as specified by ESV

Under regulation 10(5) - amend the management plan when instructed to do so by ESV within 14 days or such longer period as specified by ESV

Under regulation 10(6) - not contravene a requirement of a management plan approved by ESV

Under regulation 10(7) - Ensure that a copy of the management plan is;

Under regulation 10(7)(a) - published on the responsible persons website; and

Under regulation 10(7)(b) - available for inspection by the public at the responsible person’s principal office in the State during normal business hours.

The copy of the ELCMP on the UE website will be updated upon acceptance of the ELCMP by ESV. To ensure that the submission of the ELCMP occurs within the required regulatory timeframe, the ELCMP is submitted by the Network Risk, Safety and Technical Compliance Manager from, and recorded, in United Energy’s ESV correspondence register [email protected]. Progress of the ELCMP is monitored at United Energy’s monthly Fire Prevention Committee Meetings under the “Annual Program of Activities” standing agenda item at each the meeting.

7 Compliance with the Regulations

The Electricity Safety (Electric Line Clearance) Regulations 2015 require UE to submit an ELCMP each year to ESV for review and approval. The ELCMP has been developed to addresses the requirements of the Electricity Safety (Electric Line Clearance) Regulations 2015.

United Energy report UE RP 2804 Electricity Safety (Electric Line Clearance) Regulations Compliance Obligations reviews the Electricity Safety (Electric Line Clearance) Regulations 2015, identifies United Energy’s compliance obligations and provides evidence of compliance.

8 Service Area Characteristics

The purpose of this section is to describe the UE geographic area in sufficient detail to provide an appreciation of the vegetation management issues associated with UE’s operating environment.

UE is a regulated, Victorian electricity distribution business that was established in 1994 as result of the dis-aggregation of the State Electricity Commission of Victoria, and the amalgamation with Box Hill and Doncaster Municipal Electricity Undertakings.

UE’s electricity network is largely urban. It covers 1,472 sq.km and serves customers throughout Melbourne’s south-eastern suburbs, and the Mornington Peninsula. It includes about 600,000 residential customers, 56,000 business customers, and 4,000 commercial and industrial customers (96 take supply at high voltage), with total demand of 7,700 GWh.

The UE electricity distribution network facilitates the transport of electrical energy from ten, Ausnet Services’ terminal stations to UE’s 47 zone substations, 13,200 distribution substations and eventually onto the 660,000 customers.

mailto:[email protected]




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The northern part of the service territory is urban with a mixture of residential and commercial customers, located entirely within the Melbourne metropolitan area, bordered by Port Philip Bay and other urban areas. The southern part of the service territory is a mixture of developed and undeveloped land. It includes the city of Dandenong, and the city of Frankston which is located on the southern rim of the Melbourne metropolitan area and the gateway to the Mornington Peninsula.

The 720 sq.km Mornington Peninsula separates Port Phillip Bay and Western Port Bay, and is bounded by Bass Strait. It represents 50% of UE’s territory, with a coastal boundary of over 190 km.

Temperatures across the region range from a low of -3 degrees C to high of 46 degrees C, an average rainfall of 650mm across 150 rain days, with winds mainly from the south west quadrant with maximum wind gusts up to 120km/h.

The number of total fire ban days per year across the region (central district), for the period 1986-2015), varied from one to seven.

United Energy distribution region

Although geographically small (about one per cent of Victoria’s total land area), the UE electricity network supplies 24% of Victoria’s electricity customers, across 8% of Victoria’s power lines (12,800km) supported on 16% of Victoria’s power poles (215,000). About 20% of the network is underground (2,600km), and 80% of the network is overhead (10,200km) with 110,000 public lighting lanterns and 375,000 overhead LV service lines.

About 60% of the geographic area is located in Hazardous Bushfire Risk Areas (HBRA), and 40% in Low Bushfire Risk Areas (LBRA).

Most of the overhead network is located in LBRA (195,000 spans and 366,000 LV overhead service lines): with about 73,000 spans of HV overhead powerline, most of these with vegetation. Less of the overhead network is located in HBRA 19,000 spans and 9,000 LV overhead service lines) mainly on the Mornington Peninsula: with 14,000 spans of HV overhead powerline, about half of these with vegetation.

Vegetation in the vicinity of LV overhead powerlines presents a risk of electrocution and a lower risk of fire ignition (lower probability of fire ignition, with less consequence in LBRA). The greater risk is electrocution, especially to the public in LBRA.

Vegetation in the vicinity of HV overhead powerlines presents a risk of electrocution and a greater risk of fire ignition (greater probability of fire ignition, with greater consequence in HBRA). The greater risks are electrocution, especially line workers and fire ignition, especially in HBRA.

UE carries out regular audits of the status of the vegetation clearance space around the overhead powerlines managed by UE. Instances of encroachment on the vegetation clearance space, identified by UE’s audit program, are actioned by UE, or referred to the responsible persons for action, as required by the Regulations. [NOTE: In this ELCMP, responsible persons has the same meaning as the Electricity Safety Act].

The vegetation clearance space near bare overhead powerlines, in declared areas (about 90% of all overhead powerlines), is managed by the 14 municipal councils, or UE, as specified in the Regulations.

The vegetation clearance space near insulated LV service cables is generally managed by the property owner or UE, as specified in the Regulations.

In the inner suburbs (low bushfire risk, declared areas) the vegetation clearance space near bare overhead powerlines is characterised by various large species, planted on public land many years ago, and managed by councils.

Ringwood

Moorrabin

Melbourne

Dandenong

PORT PHILLIP

Mornington

Rosebud

Cranbourne

PortseaMORNINGTON

PENINSULA

Mordialloc

BELLARINE

PENINSULA




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In the inner suburbs (low bushfire risk, declared areas) the vegetation clearance space near LV insulated service lines is characterised by various large species, planted on private property many years ago, and generally managed by the land owner or UE.

In the rural areas (high bushfire risk, non-declared areas) the vegetation clearance space near bare overhead powerlines is characterised by various large species, planted on public land many years ago, and generally managed by UE.

In the rural areas (high bushfire risk, non-declared areas) the vegetation clearance space near LV insulated service lines is characterised by various large species, planted on private property many years ago, and generally managed by the land owner or UE.

9 UE Geographic Area

The purpose of this section is to define the geographic area applicable to this plan.

The UE service area is indicated by the blue line shown in the map below, and includes the suburbs bounded by:

the Yarra River in Templestowe, to the north

the entire Mornington Peninsula to the south

Port Philip Bay up to St Kilda to the west

Hallam to the east.




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Figure 1- UE — Geographic Area

More detail of the network assets located in the geographic area is stored in the UE GIS system called “iView.

United Energy FPP6: Annual Program of Activities Procedure, and FPP8: Coordination with Other Authorities Procedure (see United Energy Fire Prevention Plan) detail United Energy’s consultation with other authorities.

HBRA / LBRA boundaries are determined by the Country Fire Authority (CFA) in consultation with United Energy and local municipalities. The last review was conducted in 2014. Future reviews of these boundaries are subject to a request to the CFA. United Energy meets regularly with the CFA, and HBRA / LBRA boundaries are confirmed with the CFA as part of the annual ELCMP revision process.

United Energy also subscribes to the Lawlex service and as such receives notification of all Australian legislative changes and alerts. Declaration dates, and changes to HBRA/LBRA boundaries are also monitored by EnergySafe Victoria, and the information shared with United Energy.

An example of the detailed information stored iView, as well as the HBRA and LBRA boundaries is shown in Figure 2 below. This is accessible to authorised personnel via the normal login procedure and is located under “Start menu/All Programs/ Smallworld GIS/iView”, select the “Display” menu icon and then select:

“Fire Areas” and turn on low and high fire area

“Rasters” and turn on aerial photography.

An example of a HBRA-LBRA interface at the foot of Arthurs Seat is shown below.




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Figure 2. UE — Location of Trees, foothills of Arthurs Seat

Legend

Non Red Areas = LBRA

Red Areas = HBRA

Red Lines = 66kV Lines — a right click on these lines will identify the line

Blue Lines = 22kV Feeders — a right click on these lines will identify the feeder

Maroon Lines = LV Overhead Lines

Red Dotted Lines = LV Underground Assets

Circle with “P” = Distribution Substations

Purple Numbers = LIS Numbering System

Thin Maroon lines = Customer Service Lines

Yellow Diamonds = LV Open Points

10 UE Vegetation Management Zones

UE geographical area is be segregated in to four distinct management zones.

Vegetation Management Zone 1 is predominately located within the Southern Peninsula

Vegetation Management Zone 2 is predominately located between Mornington and Dandenong

Vegetation Management Zone 3 is predominately located within the northern bayside suburbs of the UE area

Vegetation Management Zone 4 is predominately located within northern suburbs of the UE area

Active Tree Services (ATS) will be the cutting SP assigned to Zones 1 & 2, and Eastern Tree Services (ETS) have been allocated zones 3 & 4. Select Solutions will cover all 4 management zones in their role as inspection services provider.

The map below depicts these zones.




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11 Structure, Roles and Responsibilities

11.1 United Energy Management / Service Provider Structure

Electric line clearance activities are managed through the same reporting structure as other asset management activities. This management structure provides the necessary responsibility, authority and accountability framework.

UE is the Responsible Person and as such responsible for compliance with the requirements of the Regulations. UE has appointed three Service Providers (SPs).

Active Tree Services (ATS) will be the cutting SP assigned to Zones 1 & 2, and Eastern Tree Services (ETS) have been allocated zones 3 & 4. Select Solutions will cover all 4 management zones in their role as inspection services provider.




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11.2 ELCMP Roles and Responsibilities

Board of Directors; have the ultimate responsibility for ensuring that UE prepares an ELCMP that complies with the Electricity Safety (Electric Line Clearance) Regulations 2015, and approved by ESV.

Chief Executive Officer; has overall responsibility for all activities relating to performance of the UE electricity network in a manner that complies with the approved Electric Line Clearance Management Plan.

General Manager Networks, Electricity; has the responsibility for approving the Electric Line Clearance Strategy and the Electric Line Clearance Management Plan

General Manager Asset Management has the responsibility for the preparing the Electric Line Clearance Strategy and formulating CAPEX and OPEX budgets and programs to achieve compliance with the Regulations

Network Risk, Safety and Technical Compliance Manager; has the responsibility for reviewing the Electric Line Clearance Strategy and the ELCMP to ensure compliance with the Regulations and the timely submission of the ELCMP to ESV.

General Manager Service Delivery; has the responsibility for delivering all of the vegetation management activities in accordance with the approved ELCMP

Head of Service Delivery (Electricity) has the overall responsibility for the deployment of UE personnel, works programs and procedures in accordance with the approved ELCMP.

Vegetation Manager; is responsible for reviewing the ELCMP as well as reporting, monitoring and auditing programs and procedures to confirm that the work is being completed in accordance with the approved ELCMP.

Fire Prevention Manager; is responsible for the preparation of the ELCMP as well as the ongoing monitoring of performance of the key functions related to fire prevention activities.

Vegetation Planner/Auditors, Liaison Officer, Performance Officer; are responsible for the day to day monitoring the KPI’s associated with the approved ELCMP, including safety and quality auditing, the delivery of works programs, fault investigations and liaison with key stakeholders.

Vegetation Service Provider’s (VSP’s); have overall responsibility for the day to day activities associated with the inspection and cutting activities, including the collection and validation of data and the provision, performance and management responsibility of all employees and sub-contractors engaged on the implementation of the approved ELCMP.

Vegetation Service Provider Inspections (VSPI); the day to day activities associated with the vegetation inspection, negotiation and notification management, including the collection, validation and recording of data, the provision, performance and management of all employees and sub-contractors engaged on the implementation of the approved ELCMP.

Vegetation Service Provider Cutting (VSPC); the day to day activities associated with the cutting activities, including the collection and validation of data, the provision, performance and management of all employees and sub-contractors engaged on the implementation of the approved ELCMP.


Document Number: UE PL 0010 Version 5.0 – September 2017

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UE ELECTRICITY NETWORK GROUP

Figure 3 - UE Management / Service Provider Structure

General Manager Networks, Electricity

UE Board of Directors

UE Chief Executive Officer

General Manager Service Delivery

Fire Prevention Manager

Network Risk, Safety and Technical Compliance Manager

THE UE ELECTRIC LINE CLEARANCE STRATEGY

(Doc № UEPL 2040)

The strategy dictates the management practices UE is to

implement to meet regulatory compliance and company objectives

THE UE ELECTRIC LINE CLEARANCE PLAN

(Doc # UEPL 0010)

The ELCMP documents the processess and procedures utilised

by UE to achive regulatory

compliance and objectives of the strategy.

Vegetation Planner Auditor/s Vegetation Liaison Officer

Contract Performance Officer

Head of Service Delivery (Electricity)

UE Service Providers

Responsibilities Include- Provide the necessary management and field resources to complete the activities outlined in the ELCMP Timely completion of the UE Electric Line Clearance programs

Provide management and field resources to implement the ELCMP. Monitoring training and competency of all personnel and service providers involved in the ELCMP activities Investigate and provide vegetation fault or outage reports when required as per FPP16

Provide Safety and Quality Auditing reports as required including rectification of any actions from such reports Manage the collection, uploading and storage of critical information Co-ordinate and liaise with councils and customers to implement the ELCMP activities

Comply with the use of vehicles and equipment and other requirements of the UE Fire Prevention Plan

UE SERVICE DELIVERY GROUP

General Manager Asset Management

Vegetation Manager




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11.3 Responsible Persons – Contact Details

For the requirement of regulation 9(3), (a), (b), (c), (d) and 9(9), the following prescribed contact details are provided:

Regulation 9 Specification – Contact details

(3)(a) The name, address and telephone number of the responsible person:

Tim Rourke Chief Executive Officer United Energy Pinewood Corporate Centre Level 3, 43-45 Centreway Place Mt Waverley VIC 3149 Phone: (03) ) 8846 9880 (via UE Switchboard)

(3)(b) The name, position, address and telephone number of the person who was responsible for the preparation of the Plan:

Trevor Fisher Fire Prevention Manger United Energy Pinewood Corporate Centre Level 1, 43-45 Centreway Place Mt Waverley VIC 3149 Phone: (03) ) 8846 9880 (via UE Switchboard)

(3)(c) The name, position, address and telephone number of the persons who are responsible for carrying out the Plan:

Ross Musgrove General Manager Service Delivery United Energy Pinewood Corporate Centre Level 1, 43-45 Centreway Place Mt Waverley VIC 3149 Phone: (03) 8846 9880 (via UE Switchboard)

(3)(d) The telephone number of a person who can be contacted in an emergency that requires clearance of an electric line that the responsible person is required to keep clear of trees:

24 Hour Dispatch and Control Centre United Energy Pinewood Corporate Centre Level 1, 43-45 Centreway Place Mt Waverley VIC 3149 Phone: 132 099 (via the UE Faults and Emergency)

(9) A responsible person must ensure that a copy of the management plan is available for inspection by the public at the responsible person’s principal office in the State during normal business hours.

On receipt of ESV’s approval a copy of 2017/18 ELCMP will be loaded onto the UE website via the following link; https://www.unitedenergy.com.au/safety/vegetation-and-powerline-clearance/ A copy of the approved ELCMP, together with a list of suitable species for planting under powerlines and the details of the cyclic cutting program is available for viewing by the public at United Energy Pinewood Corporate Centre Level 1, 43-45 Centreway Place, Mt Waverley, upon request and by arranging an appointment with: Mike Tshaikiwsky Network Risk, Safety and Technical Compliance Manager, United Energy Pinewood Corporate Centre Level 1, 43-45 Centreway Place Mt Waverley VIC 3149 Phone: (03) 8846 9550 (via switchboard) Email: [email protected]

https://www.unitedenergy.com.au/safety/vegetation-and-powerline-clearance/

https://www.unitedenergy.com.au/safety/vegetation-and-powerline-clearance/




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11.4 Appointment of Service providers

UE has appointed three Vegetation Service Providers (VSPs) to manage its day to day inspection and cutting activities.

Select Solutions (SS) has been appointed as the vegetation service provider’s inspection (VSPI) for the entire UE network.

Active Tree Services (ATS) and Eastern Tree Services (ETS) have been engaged by UE as vegetation service providers cutting (VSPC) to ensure UE’s compliance obligations are met.

11.5 General Requirements

The VSPI will inspect the UE electricity network, record the vegetation status and notify, consult or negotiate with customers, councils, land owners, occupiers and affected persons on vegetation management issues.

The VSPC will cut or remove trees, mulch branches, remove regrowth, dispose of debris, clean-up the work site, and report the progress of works to UE on a regular basis. A limited amount of mechanical slashing of undergrowth in existing easements, stumps grinding and management of trees in other areas, may also be required.

All debris should be removed within 24 hours of completion of the work. Weather conditions and the location of debris stacking shall be considered to avoid creating a safety hazard.

In circumstances beyond the control of the VSPC, debris may remain on site for up to 3 working days provided it is located and stacked in a manner that it does not present safety or tripping hazard to the general public or livestock in all weather conditions.

Vegetation management will be carried out along established UE power line corridors. Additional vegetation clearing may also be required by, and to the satisfaction of, the relevant UE employee. All clearing activity shall comply with the requirements of the Code and the approved ELCMP.

11.6 Specific Requirements

In accordance with the ELCMP, UE requires the following work to be completed on an annual basis:

Inspect, cut and remove trees in LBRA on a 2 year cyclic program (50% of the network in LBRA, annually). In the alternate year of this 2 year cyclic program, selectively inspect, cut and remove trees in the other 50% of the LBRA network that have been previously identified as spans that have been deemed unlikely to remain compliant for the 2 year cycle (short cycle spans).

Within the HBRA this work is to be completed before, and maintained for the declared fire danger period, from the declaration date for the fire danger period or 1 December whichever occurs first.

Provide all tree related Fire Prevention Index (FPI) data and complete all works necessary to keep the FPI at zero during the declared fire danger period or post 1 December.

Identify locations where work is required to maintain the vegetation clearance space: record, maintain and upload all data to the Vegetation Management System

Manage all customer liaison activities: notification, consultation, negotiation, vegetation enquiries, work coordination and actioning all vegetation reports and issues and upload all data to the Vegetation Management System

Manage and liaise with councils, land owners, occupiers, customers on contiguous lands, and other interested parties regarding all ELC matters.

Emergency response to tree related faults from storm damage within the nominated time frame

Monthly performance reporting of Key Performance Indicators;

Feeder compliance audits




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12 Definitions

As far as practicable Has the same meaning as in the Electricity Safety Act.

Code Code of Practice for Electric Line Clearance as defined in the Schedule of the Electricity Safety (Electric Line Clearance) Regulations 2015.

Declared Area An area of land in an urban area which has been declared by order of the Governor in Council, and published in the Government Gazette.

Electric Line Clearance Management Plan (ELCMP - the Plan) This document, the Plan, prepared for and approved by ESV in compliance with the Electricity Safety (Electric Line Clearance) Regulations 2015.

ESV Energy Safe Victoria (ESV) is Victoria’s electricity, gas and pipeline safety and technical regulator.

Hazardous Bushfire Risk Areas (HBRA) An area that a fire control authority has assigned a fire hazard rating of “high” under section 80 of the Act; or an area that is not an urban area and hasn’t been assigned a fire hazard rating of “low” under section 80 of the Act.

Low Bushfire Risk Areas (LBRA) An area that a fire control authority has assigned a fire hazard rating of “low” under section 80 of the Act; or an urban area.

Vegetation Service Providers (VSP) The Vegetation Service Providers (VSP) refers to the organisation/s contracted by UE to implement and deliver the requirements of the Plan.

Responsible Person (RP) Has the same meaning as in the Electricity Safety Act.

Suitably Qualified Arborist For the purposes of this ELCMP the definition of a “suitably qualified arborist” has the same definition as contained within the Electricity Safety (Electric Line Clearance) Regulations 2015.

United Energy (UE) UE is an electricity distribution company that distributes electricity to the southern and eastern suburbs of Melbourne and the Mornington Peninsula, Victoria.

For other definitions, refer to the Electricity Safety Act 1998, Electricity Safety (Bushfire Mitigation) Regulations 2003 and the Electricity Safety (Electric Line Clearance) Regulations 2015.

13 Attachments

A.1. Customer Notification Letter A.2 Customer Notification Letter - Change from Previous Cutting Practices or Methods A.3 Customer Notification Letter – Contiguous Land A.4 Customer Notification Letter – Urgent Cutting or Removal has been undertaken A.5 Customer Notification Letter - Trees of Importance, Cultural or Environmental Significance A.6 Customer Notification Letter–Service Lines (SAMPLE) A.7 UE Brochures and Advertisements A.8 Example - Newspaper Advertisement A.9 Example – ESV Letter Supporting Compliance B.1 Copy of Schedule 2 Code of Practice for Electric Line Clearance

14 References

Electricity Safety Act 1998.

Electricity Safety (Bushfire Mitigation) Regulations 2013.

Electricity Safety (Electric Line Clearance) Regulations 2015.

Electricity Safety (Installations) Regulations 2009.

UE Electricity Safety Management Scheme (ESMS)




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UE Fire Prevention Plan. (UE PL 0009)

UE Electric Line Clearance Strategy (UE PL 2040)

UE Customer Disputes/Complaints/Feedback/Compliments Processes

15 Management Procedures

The Vegetation Services Agreements (VSA) between UE and its three service providers specify the documented procedures that must be employed in delivering the vegetation management service.

In addition to many other requirements, the VSA stipulate that the service provider’s operations must comply with the approved Fire Prevention Plan and the approved Electric Line Clearance Management Plan (ELCMP).

The performance of each service provider is subject to routine audits and monthly reporting.

The procedures that must be employed in delivering the vegetation management service are detailed in this section.

15.1 Selection of the Method for Maintaining Clearances

The purpose of this section is to outline the strategy to be employed by UE in choosing the most appropriate method of maintaining the vegetation clearance space between powerlines and vegetation. The procedures apply to all persons associated with the vegetation management program.

In general all cutting on the UE network shall be in accordance with AS 4373, where it is as far as practicable to do so by the use of:

Suitably qualified or experienced personnel

Training and induction

Appropriate plant and equipment

Verification of cutting standards (auditing)

Actions to resolve pruning not in accordance with AS4373.

[NOTE: In this ELCMP, “practicable” and “as far as practicable” has the same meaning as the Electricity Safety Act].

In some circumstances it may not be practical to adhere to AS 4373. Cutting in these circumstances is clarified in Section 15.4.1.

The UE, Vegetation Manager is responsible for overseeing the development and implementation the vegetation management program. A comprehensive, routine, monitoring, audit, reporting and review process has been established to confirm the effectiveness of the vegetation management programs in achieving UE’s objectives.

To ensure the effectiveness of the vegetation management program, the inspection/pruning program cycles are reviewed by the vegetation manager, on each occasion that the ELCMP is reviewed, annually. The current inspection/pruning program cycles are detailed in the maintenance of vegetation clearance space section below.

The identification, evaluation and merit of alternate compliance methods are referred to the General Manager, Asset Management for assessment and implementation.

Where trees that are not the responsibility of UE have been identified as needing cutting or removal, the ORP’s are notified requesting that the tree(s) be cut or removed.

Where trees that are the responsibility of UE have been identified as needing cutting or removal, the VSPI determines the most appropriate method. Due consideration is given to the specific aspects of each site, including:

The significance of the site as a natural habitat for rare or endangered species, both flora and fauna

Areas determined by the relevant municipal council to contain culturally or environmentally significant trees, or trees specified in planning schemes to be of ecological, historical or aesthetic significance

Impact on the tree’s amenity and utility value if subjected to cutting versus removal

Assessing the benefit of implementing, available, practicable, alternative line construction methods

The reduction in risk to public safety and supply reliability

Significance and public value of the site’s aesthetics

Opportunity to replace the tree with a more suitable species over time

Environmental impact of proposed works

The information gathered during these inspections forms the basis of the SP’s plan of action and allows:




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Appropriate planning and scheduling

Adherence to AS 4373

Identification and quantification of the equipment and accredited personnel required

Required funding

Degree of community and customer consultation.

Where an area has been identified as having particular significance and has been accepted/registered by Heritage Victoria, the special conditions imposed will be recorded on the Important Tree VMS database and treated accordingly.

Alternative methods for maintaining clearances may be line relocation, offset crossarm construction, undergrounding or any other alternative compliance mechanism approved by ESV. The costs of implementing the alternative compliance method will be calculated on the basis of actual costs to be incurred, offset by an allowance for future savings associated with cutting work that will no longer be required.

A detailed inspection of each site is conducted by the VSPI to gather information to help determine the most effective method of maintaining the statutory vegetation clearance space between trees and overhead powerlines.

15.1.1 Calculating Applicable Distance (Spans <100m)

Sag and sway calculations for spans <100m are not required for graphs 1, 2, 3, and 4 as the applicable distances specified in the Electricity Safety (Electric Line Clearance) Regulations 2015, “Schedule 2” titled “Applicable distance for the middle two thirds of a span of electric line” include an allowance for sag and sway.

An additional distance, to allow for sag and sway, has been calculated for graphs 5 and 6, specified in schedule 2 of the Electricity Safety (Electric Line Clearance) Regulations 2015. The powerline graphs 5 and 6 specified in schedule 2 of the Electricity Safety (Electric Line Clearance) Regulations 2015 have been extended to allow for sag and sway, and included as Attachment B.2 of this plan.

VSPI representatives refer to the graphs contained in this plan for spans <100m, and a re-growth space is added to the AD to determine how distance required to maintain clearance throughout the two-year cycle.

15.1.2 Calculating Applicable Distance (Spans >100m)

The UE network has about 3,000 overhead powerline spans that are longer than 100 metres, many without vegetation.

An additional distance, to allow for sag and sway, has been calculated for graphs 1, 2, 3, 4, 5 and 6 specified in schedule 2 of the Electricity Safety (Electric Line Clearance) Regulations 2015 to cater for all United Energy span lengths.

These additional distances were determined using the applicable stringing charts, the span length and the conductor type.

The powerline graphs 1, 2, 3, 4, 5, and 6 specified in schedule 2 of the Electricity Safety (Electric Line Clearance) Regulations 2015 have been extended to allow for sag and sway and included as Attachment B.2 of this plan.

These graphs are used by UE and its SP’s in determining the required applicable distance.

These results will be shared with UE SPs and Councils.

15.2 Maintenance of the Vegetation Clearance Space

The purpose of this section is to outline the process to be employed by UE in maintaining the vegetation clearance space between powerlines and trees. This procedure applies to all persons associated with the vegetation management program.

In accordance with the Regulations 9(3)(i)(ii) UE has established management procedures and cutting cycles to manage trees and maintain the vegetation clearance space required by the Code. The cutting cycle frequency at each locality may be increased, by the VSPI in consultation with UE management.




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15.2.1 Procedure

To determine the location where work is required to maintain the vegetation clearance space, the VSPI makes uses the following inspection programs:

Routine inspection, and vegetation cutting or removal on a 2 year cycle in LBRA and HBRA

An additional annual pre-summer inspection, and vegetation cutting or removal in HBRA

Inspection and reporting of trees in declared areas (councils), is currently carried out in conjunction with the UE cyclic program.

Additional locations where work is required to maintain the vegetation clearance space can be reports from the public, line crews and asset inspectors.

The VSPI submits regular reports to UE on the observations made during the vegetation inspection program, and UE conducts regular quality audits on the progress of the vegetation management program. The results of the vegetation inspection and removal program are recorded in the UE vegetation management system (VMS).

At each location the VSPI determines the most appropriate method of maintaining the vegetation clearance space between trees and powerlines in accordance with the procedure described above: Selection of a Method for Maintaining Clearances.

The appropriate vegetation clearance space has been established, in accordance with the Electricity Safety (Electric Line Clearance) Regulations 2015, and detailed in Attachment B.

15.2.2 Regrowth Space

The regrowth space as described in the Code is “… the smallest space such that if a tree were cut or removed from that space, the tree would not grow into the minimum vegetation clearance space around that powerline between cutting times;”.

In determining the regrowth space, the VSP considers:

The tree’s species and likely growth vigour

The current two-year cutting cycle

The prescribed vegetation clearance space

In addition to considering the health and aesthetics of the tree, when the regrowth space is calculated, every effort will be made to avoid the requirement for urgent cutting or removal work.

15.2.3 Hazard Trees

The purpose of this section is to describe how the routine inspection cycle adopted by UE includes the identification of the potential hazards associated with trees within the vicinity of UE overhead powerlines. Typically these include:

Dead or dangerous limbs

Physical defects in trees such as splitting, dry rot, root plate uplift

Trees or limbs outside the vegetation clearance space that may become unstable and fall onto the powerline under the environmental and weather conditions that could be reasonably expected in the locality

Unanticipated regrowth

Vegetation found to be inside the clearance space after declaration date.

The observations and results of routine inspections are recorded in the UE vegetation management system (VMS), and the subject of regular audit by UE’s vegetation group.

Where a potential hazard tree has been identified, either as a result of a routine inspection, a report from a customer or a field crew, a suitably qualified arborist conducts an assessment of the tree, and if the assessment confirms the likelihood of contact with an overhead powerline, considering foreseeable local conditions, the tree may need to be cut or removed.

The SP notifies the customer, or the responsible person (council), via a standard notification letter of the need to cut or remove the tree. The process including any follow up actions is recorded and monitored using the United Energy VMS.

During the routine tree cutting and removal cycle, and under emergency situations, unacceptable hazards are addressed to ensure that the vegetation clearance space remains free of foreseeable tree hazards.

The foreseeable local conditions that are considered to identify trees that could become a powerline hazard include:




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Local vegetation knowledge, especially trees that were previously shaded from prevailing winds

Soil conditions

Prevailing weather conditions, wind, rain, heat

Assessment of the land contours in the area, valleys or saddles between hills

Observations by the Country Fire Authority (CFA) in preparation for the fire danger period

Features of a tree identifiable to a qualified arborist or horticulturist.

While many trees in the vicinity of a powerline have the potential to contact conductors, it is generally not practical or environmentally acceptable to remove all of these potential hazard trees. Where a hazard tree is identified, it will be listed and monitored in the Hazard Trees Register, and actioned in accordance with the requirements of the Regulations, depending on the assessed urgency and risk.

15.2.4 Planned Cutting in the Hazardous Bushfire Risk Area

Tree inspection, cutting and removal in the HBRA is carried out under the prescribed 2 year cyclic program. Prior to the declaration of the fire danger period, UE will conduct inspections within the HBRA to ensure the cyclic program meets the objectives of the regulations in relation to powerline clearance.

The observations and results of routine inspections are recorded within the UE vegetation management system (VMS), and the subject of regular audit by UE’s vegetation group.

Removal of trees is subject to negotiation with each individual, affected party following notice in writing in accordance with this Plan.

Progress of the work is monitored against the schedule drawn up before each cutting season:

Inspect and cutting programs are planned for each area to coincide with the 14 – 60 day notification periods. When finalised these programs are loaded into the United Energy VMS, and form the “works program” for the vegetation inspectors, and cutters. Completion of the work is progressively recorded in the VMS, reviewed and reported monthly by the United Energy Service Delivery team. This reporting forms the basis of United Energy’s reporting to ESV. The KPIs and measures specified by the ESV reporting guidelines are used to monitor the progress, and completion, of the inspection and pruning programs.

15.2.5 Urgent Cutting or Removal Works

Urgent cutting or removal of trees is generally only carried out where there is an imminent risk to public safety

or the continuity of supply. This cutting or removal is at the discretion of the VSP (generally fault crews for an emergency situation or trees specialists if they are called on-site) following consideration of:

the encroachment or growth of trees that was not anticipated in the management plan

a tree falling or becoming damaged so that it is required to be cut or removed to maintain the vegetation clearance space

an arborist’s assessment under Clause 14(2) of the Code that confirms the imminent likelihood of contact with an electric line having regard to foreseeable local conditions

Observations in relation to hazard tree assessments are recorded within the UE VMS and these records are managed and are maintained within the UE VMS.

the fire danger period declared under the Country Fire Authority Act 1958.

Where urgent cutting or removal has been undertaken in accordance with Clause 13 of the Code, and as soon as practicable after completing the cutting or removal, the vegetation manager will ensure a written notice (see Attachment A.4) of the cutting and removal is provided to:

The occupier of the land where the trees were cut

The owner of the land where the trees were removed.

Details are recorded and kept for a period of no less than five years in the UE vegetation management system (VMS), and include:

Where and when the cutting was undertaken

Details of why the cutting or removal was required

The last inspection of that section of the electric line where the cutting or removal was required.

Where urgent cutting is necessary the extent of cutting is restricted to a maximum distance of one metre beyond the appropriate vegetation clearance space (including a distance allowed for regrowth, sag and sway of the conductors).




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15.3 Vegetation Code Definitions and Actions

The purpose of this section is to describe the codes used by UE to document the non-compliances identified during vegetation inspection, The codes are recorded by pole number, clearly identify the non-compliant span, and assign the action period for vegetation managed by UE.

The notification, communication and recording process for the identified council and customer non-compliances shall be managed in accordance with this plan.

UE and its VSP may agree on alternative timeframes to those indicated in the tables below to cater for:

Ongoing negotiations with stakeholders (eg; :removals)

Possible engineering solutions

Access restrictions

In HBRA, during the fire season, spans requiring alternative (normally extended) timeframes must be documented by the UE Vegetation Manager together with the reasons for the alternative timeframe and any additional precautions (eg; re-assessments etc.…) that may need to be put in place to minimise risk.

This documentation is then presented to the UE Fire Prevention Committee at their next scheduled meeting for review. It is not expected any spans that have had to undergo a re-assessment under the above criteria would extend beyond 4 weeks from original overdue date.

15.3.1 United Energy HBRA Vegetation Management Codes

Code Description Action Required

PT1

(Urgent)

Means vegetation that is an immediate risk to the public or network.

Vegetation identified as an immediate risk to the public or network must be phoned through to the UE network control room

PT 1

Means vegetation that is within the vegetation clearance

space as defined in the Electricity Safety (Electric Line Clearance) Regulations, and is:

In contact with bare conductors, or uninsulated

assets with the potential to become live; or

has been contacting the conductor due to sag,

sway or environmental conditions, but is not physically in contact on the day of inspection; or

in solid contact with a HV ABC.

Vegetation identified as PT1 in HBRA must be cleared to

compliance in accordance with the following scenarios and timeframes:

vegetation identified between the end of a

declared fire season and prior to 10 October is to be cleared within 30 days

vegetation identified or outstanding after 10 October must be completed within 5 days of being identified;

vegetation that is either identified or outstanding after 1 December, or the beginning

of the declared fire season (whichever comes first ), must be cleared within 48 hours of being identified;

vegetation identified or outstanding must be cleared or other measures put into place before

a day of total fire ban, or a day of code red.

PT30 Means vegetation that is within the vegetation clearance

space as defined in the Electricity Safety (Electric Line

Clearance) Regulations 2015, and is:

Not in contact with bare conductors or

uninsulated assets and unlikely to make contact before 30 days; but likely to make contact within 60 days; or

likely to make contact with HV ABC within 30 days; or

in hard contact with a service cable or LV ABC,

with potential to cause abrasion or damage to the insulation of the conductor.

Vegetation identified as PT30 in HBRA must be cleared to compliance within 30 days of being identified; or an alternative timeframe may be agreed with UE as part of an

approved notification/cutting plan.




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PT60 Means vegetation that is within the vegetation clearance space or likely grow into the vegetation clearance space

within 60 days of being identified as defined in the Electricity Safety (Electric Line Clearance) Regulations 2015, and is

not going to make contact with any bare HV or LV asset within 60 days of being identified.

making only light or intermittent contact with a service cable or LV ABC; or

not causing abrasion, deviation or damage to the insulation of any insulated conductor.

Vegetation identified as PT60 must be cleared to compliance in accordance with the following scenarios and

timeframes:

vegetation identified during the un-declared fire

season period must be cleared within 60 days of being identified;

vegetation that is either identified or

outstanding after 1 December or the beginning of the declared fire season (whichever comes

first ) must be cleared within 42 days of being identified.

An alternative timeframe may be agreed with UE

as part of an approved notification/cutting plan.

PT180 Means vegetation that is not within the vegetation clearance space as defined in the Electricity Safety (Electric Line Clearance) Regulations 2015, but will likely

grow into the vegetation clearance space within 60 - 180 days of being identified.







15.3.2 United Energy LBRA Vegetation Management Codes

Code Description Action Required

PT1

(Urgent)

Means vegetation that is an immediate risk to the public or network.

Vegetation identified as PT1 must be phoned through to the

UE network control room. This vegetation is then treated as a “fault” and assessed and cleared by a UE fault crew.

PT30 Means vegetation that is within the vegetation clearance space as defined in the Electricity Safety (Electric Line Clearance) Regulations 2015, and is:

showing signs of contacting bare HV conductors but is not an immediate risk to the network; or

likely to make contact with bare HV before 60

days; or

in hard contact with LV conductors, with potential

to cause abrasion deviation or damage to the conductor or its insulation; or

likely to make contact with a HV ABC span.

Vegetation identified as PT30 in LBRA must be cleared to

compliance within 30 days of being identified; or an alternative timeframe may be agreed with UE as part of an approved notification/cutting plan.

PT60 Means vegetation that is within the vegetation clearance

space as defined in the Electricity Safety (Electric Line Clearance) Regulations 2015, and is:

not going to make contact with bare HV assets

within 60 days of being identified; or

making only light or intermittent contact with LV

assets; or

not causing abrasion, deviation or damage to the

insulation of any insulated conductor.

Vegetation identified as PT60 in LBRA must be cleared to compliance within 60 days of being identified; or an

alternative timeframe may be agreed with UE as part of an approved notification/cutting plan.

PT180 Means vegetation that is not within the vegetation clearance space as defined in the Electricity Safety

(Electric Line Clearance) Regulations 2015, but will likely grow into the vegetation clearance space within 60 - 180 days of being identified.

Vegetation identified as PT180 in LBRA must be cleared to compliance within 60 days of being identified; or an

alternative timeframe may be agreed with UE as part of an approved notification/cutting plan.



Vegetation identified as PT360 in LBRA must be cleared to compliance within 180 days of being identified; or an alternative timeframe may be agreed with UE as part of an





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15.3.3 United Energy Cutting Schedules 2017/18




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15.4 Responsible Cutting Practices

The purpose of this section is to outline the procedure to be employed to ensure that cutting or removal of trees is undertaken in a responsible manner. This procedure applies to all persons associated with the vegetation management program.

15.4.1 Adherence to AS 4373

UE, as part of the notification and consultation with the owner/occupier, will seek to preserve the amenity value of trees, and as far as practicable, and comply with the principles of AS4373 in managing the vegetation.

In some situations it may not be practical to undertake electric line clearance cutting in accordance with AS 4373.

Such instances include, but are not limited to –

where the customer insists that work not be completed to AS 4373 (Eg; limbs not cleared to growth points)

where the amenity value of the tree is insignificant to the owner/occupier,

adherence with past practices on large windrows of Pine or Cypress hedges where the use of mechanical devices is deemed a safer and more efficient method of meeting clearance requirements with little or no negative health impacts of the tree and is not economically viable cutting AS 4373.

UE will engage suitably qualified or experienced personnel to identify and assess locations where adherence to AS 4373 is deemed to be impractical. This includes the use of the appropriate plant and equipment such as mechanical pruning, for the management of vegetation.

Where it is not practicable to comply with the principles of AS 4373 while cutting a tree in accordance with the Code, the tree cutting procedures will be subject to approval by a UE vegetation management planner.

The vegetation management planner, as part of the normal auditing regime, will also undertake audits and take corrective action, as required, where pruning is not in accordance with AS 4373.

UE will notify the owner/occupier of the extent of the proposed tree cutting to achieve code compliance, with an offer of further consultation on the planned tree cutting, as required.

15.4.2 Procedures – including Training, Qualifications and Experience

The VSP ensures that the employees and sub-contractors undertaking vegetation management activities have sufficient knowledge, their qualifications, training, and authorities are current and they have the experience, and are inducted in a manner appropriate for the task to be performed to ensure that tree management activities are conducted in a safe and environmentally responsible manner.

The VSP employees and their sub-contractors must meet the following VESI and UE training and Authorisation requirements:

VESI Skills and Training Guideline

VESI Skills and Training matrix

UE PR 0006 – Qualifications and Training Requirements for Network Access

UE PR 0001- Electrical Network access.

UE requires all vegetation personnel engaged in cutting activities to be trained in accordance with UET20312 National qualification Certificate II in ESI Powerline Vegetation Control, in line with VESI requirements.

Additional vegetation specific training requirements are provided, depending on the role of the worker. The competency units or their recognised equivalents1 are mandated for each nominated type of worker prior to undertaking the specific task such as those listed below;

Ground Crew

Tree Climbers

Cutter working from EWP

Assessor

The complete Certificate II – Units of Competence Requirements are contained on the VESI website as per the link below or any subsequent updates.

1 Refers to a national Competency Standard unit from a relevant training package




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http://www.vesi.com.au/files/SkillsandTraining/Vegetation_Management/VESI_Vegetation_Guideline_V2_September_2015.pdf

Where a person performs multiple roles they shall undertake the mandatory training for each of those roles. To operate High Risk Plant and equipment (e.g. EWP) the operator shall have the applicable High Risk Licence issued by Worksafe Victoria.

Vegetation work near a live HV line can only be carried out by qualified line workers who meet the requirements of the VESI Skills and Training Guideline, the VESI Skills and Training matrix and the Minimum Rules for carrying out High Voltage Live Work.

Records are maintained by the VSP and may be audited by UE at any time.

Prior to contract commencement, United Energy reviewed all licencing and training for all tree clearing activities.

Prior to Network Access being granted, each worker was checked to ensure that they had all of the mandatory qualifications and refresher training current.

This information is recorded and stored centrally, including a list or approved workers and their functional role.

United Energy undertakes an annual training and system audit on each contractor, where the training records of all staff are audited. Staff found on site without the relevant training are subject to the disciplinary action listed in Section 8.2 of UE PR 0006 – Qualifications and Training Requirements for Network Access

Audits are undertaken, actions created and tracked in accordance with UE PR 0007 Audit and Inspection of United Energy and Multinet Field Work Sites.

The auditors have been assigned and the audit dates planned in accordance with the UE work practices audit spread sheet.

15.4.3 Herbicide Use

UE’s use of herbicides is minimal. Any employee or service provider required to carry out herbicide work shall be trained in the use of herbicides. Any change in this practice will be subject to negotiation between the UE and the VSP and will include the use of an appropriate handling regime.

15.5 Alternative Tree Management Proposals

United Energy will consider all reasonable proposals to reduce the need for tree cutting or removal. Written proposals will be forwarded to the General Manager Asset Management for consideration, accompanied by all of the information required to consider the proposal.

The General Manager Asset Management will contact the applicant within five working days and explain the process for handling the proposal, and outline any costs that may be involved in assessing the proposal.

Where the applicant wants to continue with the proposal, the General Manager Asset Management will provide the applicant with indicative costs of the proposal within 30 days. These costs will consider benefits that UE may receive from the proposal, such as reduced vegetation management costs.

15.5.1 Alternate Compliance mechanisms

The Electrical Safety (Electric Line Clearance) Regulations 2015 provide for alternative compliance mechanisms. UE is committed to working with stakeholders to ensure the safe, efficient supply and use of electricity.

Before any alternative compliance mechanism can be considered for use on the electricity network, it must be accompanied by a formal safety assessment and meet the requirements of United Energy’s product approval process.

The proposal must be supported by Manufacturer’s details:

Manufacturer’s name, type and model number of the product

Manufacturer’s certified recommendation supporting the intended use of the product

Recognised international standard(s) that apply to the product, design, manufacture, testing

Source of materials and place of manufacture

Original type, routine, endurance, environmental, factory acceptance, site acceptance, and commissioning and test reports from an accredited laboratory

Design, installation, inspection and maintenance instructions for the product

Details of service experience in similar environment

Other customers’ details






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The proposal must be supported by an engineering assessment, completed by a recognised subject matter expert, on the impact on the alternative compliance mechanism:

de-rating effect on the powerline

effect of the additional loading on the powerline

changes to existing work practices

method for inspecting the alternative compliance mechanism

cost/benefit analysis for the alternative compliance mechanism.

Currently UE does not have any alternate compliance measures in place and have not received any proposals for alternate compliance measures.

15.5.2 Long Term Strategies

In addition to implementing this Plan, to avoid trees growing into, or encroaching on the vegetation clearance space as UE has implemented a number of other strategies to minimise the risk posed by trees to the safe operation of powerlines including:

Installation of insulated (ABC) conductor and undergrounding sections of powerline subject to UE business rules

Deployment of various electrical protection devices both within substation yards and at strategic points throughout the network.

15.6 Important Trees

This section outlines the procedure employed to ensure important trees are identified and documented in the VMS, and given special consideration when and cutting or removal is proposed. This procedure applies to all persons associated with the vegetation management program.

The Important Trees are recorded electronically in the VMS against the span or as a specific tree/s. The data can accessed by running the special requirements filter in the VMS.

Screenshot of the Special Filter Tab containing Important Trees

These spans/trees are displayed on all VMS field tablets, as shown below.

Screenshot of the Field Tablet Mapping Screenshot of the Comments Layer




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UE recognises that there are some trees in the service territory that are of special importance due to their:

Species (Native/Exotic)

Ecology (identified in Planning Schemes)

History (identified in Planning Schemes)

Aesthetics (identified in Planning Schemes)

Culture (identified in Planning Schemes/Heritage Registers)

Environment (identified in Planning Schemes/Heritage Registers)

Habitat - invertebrate/vertebrate fauna (Listed as threatened in accordance with section 10 — Flora and Fauna and Guarantee Act 1988).

The VSPI will consult with stakeholders to ensure that where practicable, these trees and sites are given special consideration in planning tree cutting or removal activities, in a safe manner.

Procedure

The VSPI shall make every effort to determine the location of important trees by consulting:

State and local government records

Planning schemes and overlays

Community groups

Land owners/occupiers.

The VSPI, on behalf of UE, monitors the data contained in the Department of Environment, Land, Water and

Planning (DELWP) Threatened Invertebrate/ Vertebrate Fauna listings, at least annually.

Under section 11 of the code a responsible person must not cut or remove a tree that is habitat to threatened fauna during the breeding season for the threatened fauna unless;

(a) it is necessary to cut or remove the tree for safety reasons, or

(b) it is not practicable to undertake cutting or removal of that tree outside the breeding season

Notwithstanding these situations the cutting or removal of trees with threatened fauna is generally planned to be undertaken outside the breeding season for the species wherever practicable.

If this is not practicable the Vegetation Manager, in conjunction with the VSPI, will engage a suitably qualified, professional in the field of local fauna identification on the appropriate course of action to translocate the fauna.

UE and the VSP use the VMS to record spans where important trees have been identified, and this database is consulted when vegetation management or network augmentation work is planned.

The VSPI delivery manager consults, and negotiates with the persons responsible for important trees prior to the commencement of any work to determine the most effective way of protecting the affected trees and restricting the cutting or removal of native trees, cultural or environmentally significant trees to the minimum extent necessary to achieve the required vegetation clearance space.

Reports are provided to UE on the process and outcomes of discussions, which are subject to regular audit by the UE vegetation group.




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Actions considered by UE and the VSP to mitigate the impact may include:

More frequent cutting of the vegetation (facilitated by UE and funded by stakeholder)

CAPEX solution (facilitated by UE and funded by stakeholder).

Using these strategies will initiate greater interaction between UE, councils and other stakeholders in deciding the most appropriate methodology for maintaining vegetation clearance.

15.6.1 Species Identification

For the purposes of this plan “native trees” are defined as “trees that are indigenous to a specific area and are regarded as significant by a local government, the community or customers”

As required by regulation 9(3)(h), the locations of native trees where identified are included within the important tree register.

Additional information sources used to identify the location of important trees are listed below

15.6.2 Trees of Significance Listed in a Planning Scheme

Some municipalities have developed a listing of significant trees within their region. The VSPI (as required in regulation 9(3)(g) (ii) liaises with these municipalities to identify the trees contained within Planning Schemes that are deemed to be of ecological, historical or aesthetic significance and add them to the important tree VMS database as required.

A total of 14 Municipal Councils serve the rate payers supplied by the UE electricity distribution network. UE works closely with each of these Councils to address electricity supply and vegetation management issues to facilitate compliance with the various Acts and Regulations.

Councils Located within the UE Franchise Area

Bayside Boroondara Casey Frankston Glen Eira Dandenong Kingston

Knox Manningham Monash Mornington Port Phillip Stonnington Whitehorse

As part of the regular dialogue with councils, trees of significance, of cultural or environmental significance or

habitat trees for threatened fauna will be addressed and tree registers updated.

15.6.3 Trees that are Culturally or Environmentally Significant

UE has researched and compiled a list of trees deemed to be culturally or environmentally significant (as required in regulation 9(3)(g)(iii)). For trees of cultural or environmental significance the following resources were used:

15.6.4 Victorian Heritage Register.

The Victoria Heritage Register (VHR) is available on the Department of Transport, Planning and Local Infrastructure web site.

http://vhd.heritagecouncil.vic.gov.au/search?cat%5B0%5D=2&do=s&collapse=true&type=place&spage=1&tab=places&view=detailed&rpp=25&cp=16

The VSPI is required to check each of the records in detail and update the VMS with the relevant information required by the vegetation assessor to identify any trees on the Heritage List that may be within the UE area. The VSPI also checks the VHR for variations at least once a year.

15.6.5 Victoria Aboriginal Heritage Register.

The Victoria Aboriginal Heritage Register is available on the Department of Premier and Cabinet web site. This register is available on a need-to-know basis, due to the culturally sensitive information. The VSP either maintains an authorisation to access the register, or makes an annual application to Aboriginal Affairs Victoria to obtain a report covering the UE geographic area. The VSPI notes variations in the report from time to time.

15.6.6 Habitat Trees for Threatened Fauna

There are no specific listings of habitat trees with a conservation status of “vulnerable”, “endangered” or “critical endangered” fauna currently available in Victoria. The information sources referenced by the VSPI to try to identify these locations are:

- Flora or a Habitat of Fauna

The VSPI checks the Department of Environment and Primary Industries (DEPI) “Flora and Fauna Guarantee Threatened List” at least once every year for variations. The list is specifically referenced in section 10 of the Flora and Fauna Guarantee Act 1988 and rarely changes.




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- The Threatened Flora List, Threatened Invertebrate Fauna List and Threatened Vertebrate Fauna List

These lists are published on the Department of Environment and Primary Industries (DEPI) website.

The VSPI checks this list at least annually for variations. The list is specifically referenced under, section 5 Definitions, of the Electricity Safety (Electric Line Clearance) Regulations 2015. The list current at the time of preparing this plan was:

- Advisory List of Threatened Vertebrate Fauna in Victoria — 2013

https://www.environment.vic.gov.au/__data/assets/pdf_file/0014/50450/Advisory-List-of-Threatened-Vertebrate-Fauna_FINAL-2013.pdf

- Advisory List of Threatened Invertebrate Fauna in Victoria – 2009

https://www.environment.vic.gov.au/__data/assets/pdf_file/0016/50452/Advisory_List_of_Threatened_Invertebrate_Fauna_2009_FINAL_Sept_2009.pdf

16 Notification, Consultation and Negotiation

Procedure

This section outlines the procedure to be employed by the VSPI to notify, consult and negotiate with the:

owner (removal) or occupier (cutting) of the land where the cutting or removal is to take place,

local council, where the council is the owner of the tree but not the responsible person

the occupier of land contiguous where the use of that property may be affected from the tree cutting or removal activities. (eg; road or driveway blocked by EWP’s etc…..)

as prescribed under Schedule 1, Division 3, regulation 15 of the regulations.

This procedure applies to all persons associated with the UE vegetation management program and includes the type of notices that are required to be issued by the VSP as part of the work assessment.

Any urgent cutting or removal shall be carried out in accordance with this plan.

16.1 Notification for Cutting or Removal

The UE, Vegetation Manager is responsible for developing and managing the vegetation management program.

The VSPI will initially notify all persons in writing, in accordance with the requirements of the Electricity Safety (Electric Line Clearance) Regulations 2015, with a minimum 14 days’ notice and not more than 60 days’ notice before the intended cutting or removal is to occur.

Re-notification required as a result of notification falling outside 60 day notified timeframe, or if changed cutting practices are required to meet code requirements is usually carried out by the VSPC.

Regular audits are completed by UE to confirm that notifications have been distributed, within the 14-60 day notification period, and distributed to the right category of person. Where pruning cannot be completed within the 14-60 day period, the notification process is repeated.

The notice shall convey the following essential information:

An explanation of why compliance with the Code is essential

Why the proposed works are necessary

The tree cutting work that will be carried out and who will carry out the work

An invitation for further consultation or additional detail about the tree cutting work prior to work commencing

Name and telephone number of contact person for further consultation, additional detail, or any matters of concern

Dispute Resolution Procedure

An indication that the tree cutting works is generally the same as performed previously

Information on tree/s of cultural or environmental significance, details of the impact of the cutting or removal of the tree, and the actions to be taken to minimise that impact.

Samples of typical notification letters are in attachments in this plan as per below; o A.1. General Cutting or Removal o A.2 Change from Previous Cutting Practices or Methods o A.3 Contiguous Land o A.4 Urgent Cutting or Removal has been undertaken








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o A.5 Trees of Importance, Cultural or Environmental Significance o A.6 Service Lines

16.1.1 Published Notices

Under “Division3”, “Section 16 (3)” of Schedule 1 of the Code of Practice a when cutting or removal a tree on public land “written notice must be published under subclause (2) must be published in a newspaper circulating generally in the locality of the land in which the tree needs to be cut or removed”.

These methods of notification would include the following circumstances where the trees are deemed UE’s responsibility;

trees located on the road reserve or nature strip in undeclared (normally rural) areas, and;

trees located on public lands (Vic Roads/Water Authorities etc…) in declared (normally urban) areas other than those managed by councils

In accordance with ESV correspondence 27 November 2015, “Electricity Safety (Electric Line Clearance) Regulations 2015 – Guidance Information” which states:

United Energy shall adopt one of two methods.

1) The VSPI will provide written notification (as per Attachment A.1. Customer Notification Letter) to any residents within the vicinity of such works stating that the work will only commence between 14 and 60 days from the date of this notice; or.

2) The VSPI will place a notice in the newspaper (as per below), to make stakeholders aware of the planned cutting or removal of tree(s) on public land and stating that the work will only commence between 14 and 60 days from the date of this notice.

16.1.2 Consultation for Cutting or Removal

If the tree intended to be cut or removed is within the boundary of a private property, the VSPI will consult with the owner or occupier.

NOTICE OF VEGETATION PRUNING OR CLEARING NEAR POWERLINES

United Energy (UE) owns and maintains the poles and wires in the south eastern suburbs of Melbourne and the Mornington Peninsula. UE has a vegetation management program, which includes regular inspections by our service providers of powerlines and tree proximity to maintain an uninterrupted fire safe supply of electricity.

We recently conducted a powerline inspection that identified vegetation on public land and/or within the boundaries of private properties that requires clearing. These works are scheduled to occur in the following suburbs; Arthurs Seat, Baxter, Carnegie, Carrum Downs, Dandenong South, Dromana, Flinders, Heatherton, Hughesdale, Main Ridge, Malvern East, Merricks, Merricks Beach, Merricks North, Moorabbin, Mornington, Mount Martha, Mulgrave, Point Leo, Red Hill, Red Hill South, Safety Beach, Shoreham, Surrey Hills, Tuerong, Clayton, Dandenong North, Glen Waverley, Knoxfield, Langwarrin, Mount Waverley, Mulgrave, Noble Park North, Notting Hill, Oakleigh East, Rowville, Scoresby, Templestowe, Wantirna South And Wheelers Hill over the next 60 days in order to maintain the required clearance space around power lines. Individual properties with vegetation requiring clearing will have received notification by letter drop, 14 days prior to commencement of clearing.

Should you require further consultation or details regarding proposed pruning or clearing, please contact our Customer Service Centre on 1300 792 456 (8am to 5pm Mon to Fri).

For more information regarding United Energy’s Electrical Line Clearance plan, visit the following website address www.unitedenergy.com.au/safety/vegetation-and-powerline-clearance

http://www.unitedenergy.com.au/safety/vegetation-and-powerline-clearance




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As part of the UE written notification process, the owner or occupier will be invited to contact the nominated UE representative on the phone number provided, if required, for consultation, additional information, or to address matters of concern about the tree cutting work prior to the work commencing.

It not always possible for UE to identify or contact the property owner or occupier. Name and contact details may be unknown or subject to a confidentiality arrangement. The most practical approach is for UE to invite (encourage) the owner or occupier of the property to contact UE, and discuss any issues or concerns that they may have as part of the notification process.

Where a change to previous cutting practices or methods for the removal of trees near powerlines is being implemented UE will encourage direct consultation owner, occupier and local councils. A change from previous cutting practices or methods may be cutting further than previously, more canopy reduction or tree cutting using mechanical methods. Notice (see attachment A.2) encourages owner or occupier and local councils to contact the VSPI.

The following flowchart illustrates how the negotiation and consultation process is utilised by the VSPI to manage any customer interactions

16.1.3 Negotiation Process

The VSPI must decide on how to maintain the required clearance between powerlines and trees so that the vegetation clearance space remains free of vegetation in accordance with the section “Selection of a Method of Maintaining Clearances”. However, this does not preclude affected persons from negotiating conditions under which other solutions may be used in accordance with the section “Alternative Vegetation Management Proposals”.

As part of the negotiation process where agreement on the cutting or removal of vegetation cannot be achieved, the VSPI will advise the affected person of the UE dispute resolution procedure, and the process to be employed to negotiate alternative powerline clearance arrangements that may avoid or reduce the need for tree cutting or removal, together with any conditions that may apply to such arrangements.

The VSPI will maintain a detailed record of the negotiation process.




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Where a dispute arises during the negotiation process, between the property occupier, owner or council and the VSPI regarding the proposed cutting, removal or alternative arrangements, it shall be resolved in accordance with the UE Dispute Resolution Procedure.

Notwithstanding the nature of the dispute and the need to resolve the dispute in accordance with the UE procedure, the duty of UE to maintain the vegetation clearance space at all times shall not be compromised.

Where landowners or occupiers refuse to allow UE representatives access or permission to maintain regulatory compliance ESV will be notified of such situations for assistance. As a result ESV may issue the landowner or occupier a letter to the customer in support of UE endeavours to achieve compliance and with an example of such a letter provided in Attachment A.9 of this plan.

16.1.4 Dispute Resolution Procedure

The UE Dispute Resolution Procedure, based on attempting to resolve complaints at the earliest, lowest possible level, shall be explained all stakeholders involved. Where the dispute cannot be resolved at the lowest possible level, the process allows for escalation of the dispute to the next level of management.

The various dispute escalation levels are shown below, together with more detail on the process at each level of escalation:

1. VSPI Assessor 2. VSPI Inspections Program Leader and/or Cutting Program Leader 3. UE Vegetation Planner/Auditor 4. UE Vegetation Manager 5. Customer Operations 6. Energy and Water Ombudsman (Vic) (EWOV).

Contact Details

Position Contact Details

Reference to UE Vegetation Team

United Energy Vegetation Group

Address: Pinewood Corporate Centre

Level 1, 43-45 Centreway Place. Mt Waverley VIC 3149

Phone: (03) 8846 9880 (via UE Switchboard)

VSPI Assessor The VSPI Assessor endeavours to resolve disputes arising from the execution of their duties in a fair and reasonable manner. Disputes cost time and money and may reflect poorly on UE and the VSPI’s reputation. Disputes may be the result of a breakdown in negotiations prior to the works or as a result of dissatisfaction with the work. Every attempt will be made to settle the dispute at the first point of contact to avoid unnecessarily escalation of the incident. The VSPI Assessor will explore all options within their authority during the consultation and negotiation phase to avoid disputes.

Where the dispute cannot be resolved at this level, the affected person shall be advised of the process for escalating the dispute to the next level of management.

Reference to VSPI Inspections Program Leader Where agreement cannot be reached, the VSPI Assessor will notify the inspections program leader of the dispute and provide a “brief” of the negotiations to date. All correspondence from the affected person will be logged into the vegetation management system (VMS) for tracking. The inspections program leader will review the dispute and explore all practical options and offer additional alternatives within their authority.


Reference to VSPC Cutting Program Leader Where a dispute is related to the cutting or removal works that have been undertaken the inspections program leader will notify the cutting program leader of the dispute and provide a “brief” of the interactions that have taken place up to that point. All correspondence from the affected person will be logged in VMS. The cutting program leader will review the dispute and explore all options for the prompt resolution to the dispute and update the VMS accordingly.


Reference to the Arboreal Advisors




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While all Assessors employed by the VSPI are trained in tree identification, pruning techniques and tree physiology some special situations may require greater expertise. Advice may be sought from arborists where the dispute requires an expert third party opinion on the matter relating to the tree or trees in question.


Reference to UE Vegetation Planner/Auditor The UE Vegetation Planner/Auditor is responsible for the day to day management of the UE vegetation programs, and will investigate all issues to ensure that notification, consultation, negotiation, dispute resolution, cutting and removal has been conducted in accordance with this Plan. Issues that cannot be settled at VSP will be referred to the Vegetation Manager.


UE Vegetation Manager

The UE Vegetation Manager is ultimately responsible for the delivery of the Plan. If an issue remains unresolved at this stage the customer may wish to continue the dispute with UE.

Where the dispute cannot be resolved at this level, the affected person shall be advised of the process for escalating the dispute to the next level of management. Issues that cannot be settled with the Vegetation Manager will be referred the Customer Operations.

Customer Operations

The Customer Operations Team assume responsible for the management of direct customer complaints/disputes if an agreement is not reached between the UE Vegetation Manager and the customer.

Any agreed course of action will be recorded in an agreement and signed by the owner/occupier. In order to avoid any future dispute where the agreed action is to take place over a period of time a notation referring to the agreement will be made in the Important Tree database, maintained in the VMS.

Resolution If agreement is reached, then the agreed course of action will be recorded in an agreement and signed by the owner/occupier. In order to avoid any future dispute where the agreed action is to take place over a period of time a notation referring to the agreement will be made in the Important Tree database, maintained in the VMS.

Energy and Water Ombudsman (EWOV) / Energy Safe Victoria (ESV). Any customer who considers they have been poorly treated under this process is welcome to approach the EWOV or ESV for recourse. ESV is considered the last industry advocate available to settle tree related disputes.

Energy and Water Ombudsman (Victoria) Ltd. GPO Box 469 Melbourne 3001 Tel: 1800 500 809

Energy Safe Victoria PO Box 262 Collins Street West, VIC 8007 Tel: 9203 9700

16.1.5 Customer Complaint Process

If the dispute cannot be resolved using the dispute resolution procedure, the owner/occupier may initiate the UE, customer complaint process by contacting us on 1300 131 689, or alternatively as detailed on the UE website, and summarised below.

https://www.unitedenergy.com.au/contact-us/complaints-compliments/

This webpage can also be used for compliments and enquiries.

17 Monitoring, Reporting and Auditing

UE has developed a Vegetation Management System (VMS) which includes a set of reportable items to monitor the performance of the vegetation management program. Key items are monitored and reported by the UE Vegetation Management team on a monthly basis as part of the normal monthly reporting regime.

As a minimum the reportable items, will be the Key Performance Indicators specified in section 4 of Energy Safe Victoria “Electrical Infrastructure Safety Electrical Incident and Safety Performance Reporting Guidelines”.




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UE uses a number of measures to assess the performance of the VSP. The KPI’s are outlined in the “Vegetation Cutting/Inspection Service Agreements” and monitored on a monthly basis. An example of the VSPC KPI is outlined below.

17.1 Auditing

17.1.1 Audit Roles and Responsibilities

The accountability for auditing the performance of this Plan, the vegetation components of the UE fire prevention plan and the vegetation service agreements currently within place with the VSP including key performance indicators (KPI) rests primarily with the UE Vegetation Manager.

The UE health, safety and environment manager also undertakes scheduled audits on compliance with OH&S requirements.

Responsibility for these audits is delegated to the UE vegetation planner/auditors and/or health and safety auditors who complete scheduled field and desktop audits of the VSP to ensure that performance complies with the requirements.

Components of these audits include but not be limited to;

Compliance with Code

Quality, including pruning in accordance with the principles of AS 4373

Customer feedback, complaints, and satisfaction

Worksite Management (OH&S)

Qualifications and Competency

17.1.2 Schedule and Frequency

United Energy inspects about 110,000 spans of overhead powerline each year, and about 10,000 spans of overhead powerline in HBRA before summer each year.




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For a population of 110,000 spans, the statistically significant audit sample size, for a 95% confidence level is about 400 spans (using the Raosoft sample size calculator available on the internet).

The UE audit sample size for vegetation management activities, exceeds 400 spans per annum.

To cater for variations in the size of vegetation management activities (sample size), and simplify the audit process, as shown in the table below, United Energy has increased the audit sample size as shown in the table below.

The annual vegetation management audit program is determined by the UE vegetation manager and carried out in accordance with the “United Energy Vegetation Auditing Process” (see table of contents below).

The scope of the audit will be governed by the scope of the inspection and cutting work. Hedge rows will be treated differently to a large overhanging trees, differently to a prized private tree, and differently to an entire feeder. HBRAs will be treated differently to LBRAs. The frequency of the audit will be governed by the scope of inspection and cutting work and the rate of completion of the inspection and cutting program.

Additional audits are also to be completed at a number of levels by:

VSP,

UE Vegetation group,

UE Health and Safety group,

UE Electricity Networks team, and

ESV.

17.1.3 Recording and Managing Results

Vegetation audit results including any actions are recorded and tracked within UE’s VMS and reported as required to the;

Service Delivery Management Team

UE ESMS operations and steering committee,

Fire prevention committee

Audit and Risk committee




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The Network Risk, Safety and Technical Compliance Manager is responsible for analysing and reporting the correlation between the audit results and UE’s KPIs, following up and tracking progress on actions arising from the audit observations.

17.1.4 Summer Inspection Programs in HBRA

Within the UE HBRA a summer inspection and pruning program will be conducted annually on all or part of UE’s approximately 19,000 spans.

The vegetation manager will ensure that the VSP complete their HBRA programs by late November or earlier if and an early declaration date is anticipated.

17.1.5 Compliance with the Code

The 2 year cyclic vegetation inspection and pruning program monitors and reports on the location and status of vegetation near powerlines and records all information associated with such vegetation into the VMS.

Information from the VMS will be used to report on UE’s compliance with the regulations. A copy of the reports will be shared with ESV, monthly. The historical work programs and the program completion data will be used to test, challenge and confirm United Energy’s compliance with the regulations, as well as identify areas where remedial action may be necessary to improve deficiencies in the program, and improve performance.

The methodology utilised to confirm ongoing compliance with the code is to monitor the number of spans that remain outside of the clearance space for the duration of the vegetation clearing cyclic. Currently UE measures the level of compliance using historical data within the HBRA only, using the Summer Audit Program data.

It is UE’s intention to measure this compliance across its entire network by utilising the historical data contained within the VMS upon completion of the second vegetation clearing cycle in 2018/19.

17.1.6 Exception to minimum clearance space

Currently UE does not utilise the exception to minimum clearance space clauses within the code.

18 Assistance to Councils and Land Owners/Occupiers

UE will communicate regularly with all Councils within its territory, and liaise more closely with councils that have had difficulty in achieving compliance with the Regulations. UE will contact councils at management level to help these councils achieve compliance by raising the profile of vegetation compliance to management level and highlight the risk exposure and regulatory penalties.

UE will work closely with ESV to help councils become more compliant with the Electricity Safety (Electric Line Clearance) Regulations 2015 and address emerging issues in a timely manner.

Where non-compliant trees are identified that are a threat to the integrity of the network, and are the responsibility of an ORP or council, the VSPI will notify the ORP or council of the areas requiring attention and request the ORP or council to report the progress of vegetation clearing work, in a timely manner.

UE will also provide assistance to councils in relation to sag and sway data for all spans, as required.

UE plans to meet with councils on a regular basis. One meeting will be held with councils with HBRA in August to discuss summer preparedness programs. The timing of other council meetings may vary depending on the vegetation management issues.

COUNCIL HBRA Pre summer meeting schedule LBRA meeting schedule* (Dates may vary)

Bayside Council N/A Aug 17/ Feb-18

Boroondara Council N/A Aug 17/ Feb-18

Casey Council Aug-17 Feb-18

Frankston Council Aug-17 Feb-18

Glen Eira Council N/A Aug 17/ Feb-18

Greater Dandenong Council Aug-17 Feb-18

Kingston Council Aug-17 Feb-18

Knox Council N/A Aug 17/ Feb-18

Manningham Council Aug-17 Feb-18

Monash City Council N/A Aug 17/ Feb-18

Mornington Council Aug-17 Feb-18

Port Phillip Council N/A Aug 17/ Feb-18

Stonnington Council N/A Aug 17/ Feb-18

Whitehorse Council N/A Aug 17/ Feb-18

United Energy FPP6: Annual Program of Activities Procedure, and FPP8: Coordination with Other Authorities Procedure (see United Energy Fire Prevention Plan) detail United Energy’s consultation with other authorities.




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18.1 Interaction with Council and Land Owners/Occupiers

UE shall inspect its overhead assets and Private Overhead Electric Lines (POEL) in accordance with the Regulations and the procedures set out in this Plan.

Councils and land owners/occupiers shall be notified of their obligation, as the Responsible Person, to clear trees that are infringing on the vegetation clearance space. Follow up audits will be conducted on councils and POEL landowner/Occupiers where appropriate to ensure that action has been taken in accordance with the Code.

Upon request, the VSPI will assist councils and land owners/occupiers to safely cut or remove trees near powerlines by providing advice on:

safe work practices including safe limits of approach

the de-energising of lines

the suppression of the auto re-closing feature on HV feeders

authorised local service providers

location of HV feeders.

The VSPI will provide information to councils, land owners, occupiers and the public on the appropriate planting and maintenance of trees near powerlines. The information provided may include a copy of the brochure reproduced in the Attachments.

Each year, UE shall advise owners of POEL of their responsibilities in relation to these powerlines. In accordance with the Private Overhead Electric Lines Procedure, brochure FPP25 in the current UE Fire Prevention Plan (reproduced in the Attachments) is included in the mail-out to these customers.

UE shall notify councils, land owners, and occupiers, as Responsible Persons, of any vegetation not meeting the clearance requirements outlined in the Regulations. Where the councils, land owners, or occupiers refuse or are unable to clear the vegetation within a reasonable timeframe UE may liaise with ESV regarding any further action to be taken. See the flow chart below.

18.1.1 Declared Area Hazard Tree Rectification Process

As part of the UE vegetation inspection program, councils will be notified of trees that infringe into the vegetation clearance space and threaten the integrity of the powerline, that are the council’s responsibility. Councils will be requested to provide the required vegetation clearance space at each location within 14 days.

In the interest of public safety and supply integrity, follow up audits will be conducted to ensure that the appropriate action has been taken to achieve compliance with the Code.

Where trees have not been cut or removed to achieve compliance with the Code within the agreed period, council will be reminded of the requirements of clause 86(5) of the Electricity Safety Act 1998 and UE’s process for the management of vegetation that is council responsibility.

18.1.2 Non Compliance by Councils or Other Responsible Persons (ORP)

If there is no feedback/action in relation to the initial notification, UE (or their agent) may issue a formal “notice of failure to maintain lines” to councils or an ORP or subject to section 86(1) of the Electricity Safety Act 1998.

If there is no feedback or action in relation to the formal notice, UE (or their agent) may refer these trees to ESV requesting their agreement (via certificate) for UE (or their agent) to “… carry out the duties and perform any work necessary to ensure that the whole or any part of a tree is kept clear of the line” (refer Electricity Safety Act 1998, section 86(5)).

Where ESV or UE considers the line to be in such a dangerous condition that urgent compliance with the notice is necessary within 14 days from the date of the notice (refer Electricity Safety Act 1998, Section 86(4)) or where there is an imminent risk to public safety or the continuity of supply, cutting or removal shall be undertaken in accordance with Regulations.

UE “may recover the costs of carrying out any work… from the responsible person to cut or remove these trees (refer Electricity Safety Act 1998, Section 86(7)).

18.1.3 Management of vegetation that is Council Responsibility (Flowchart)

Is the infringing vegetation the responsibility of council?

Yes No




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18.1.4 Service Lines

Occupiers of land are responsible for inspecting and keeping trees clear of the service lines that supply their property. Where an occupier seeks advice from the UE, the VSPI will attend and advise the occupier.

Where the VSPI, as part of the routine inspection of UE assets, identifies a service line as having trees within the vegetation clearance space, a brochure (see Attachment A.7. Trees, Powerlines and Your Property) shall be placed in that customer’s letterbox advising them of the various responsibilities.

VSP to notify council in writing of the infringing vegetation and seek a response outlining the intended remedial action, timeframe.

Action infringing vegetation via normal

UE program

VSP to “brief” UE on the non-compliance/s. UE to notify council, in writing, that the non-compliance will now

be referred to ESV.

VSP to liaise with council until the infringing

vegetation is compliant

VSP to confirm that

infringing vegetation is compliant

Close out Job in VMS

Does the response (action, timeframe) from council address the non-compliance(s)?

VSP to notify council in writing of the infringing vegetation, requesting a meeting with

personnel responsible for managing vegetation, United Energy (UE) and the VSP to

develop a course of action.

No

Do the intended actions address the non-compliance(s)?

No

UE to refer the non-compliance to ESV. UE to advise VSP of any further action.

Yes




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19 ATTACHMENTS

19.1 Attachment A.1. - Customer Notification Letter (Sample)




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19.2 Attachment A.2. - Customer Notification Letter - Cutting Practices (Sample)



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19.3 Attachment A.3. - Customer Notification Letter – Contiguous Land (Sample)



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19.4 Attachment A.4. - Customer Notification Letter – Urgent Cutting (Sample)

Address: Date Issued: / / UEUC Ref:

Dear Customer,

ATTENTION: URGENT CUTTING OR REMOVAL OF TREES

Urgent cutting or removal of trees is generally only carried out where there is an imminent risk to public safety or the continuity of supply.

In accordance with Clause 18 of the Code of Practice for Electric Line Clearance, UE has a process to notify landowner/occupiers, as soon as practicable after completing the cutting or removal where urgent cutting or removal has had to be undertaken.

Where urgent cutting is necessary the extent of cutting is restricted to a maximum distance of one metre beyond the appropriate vegetation clearance space (including a distance allowed for regrowth, sag and sway of the conductors).

The reason urgent cutting or removal was carried out at your premises was as follows:

Tree or branch unanticipated growth had to be cut away from the vicinity or directly from the powerlines

Tree or Branch had failed, become unstable or declared as posing an imminent danger to the powerlines

The tree that required urgent pruning was last inspected as per below:

The tree was last inspected by UE on the XX/XX/XXXX

The tree was last cut by UE on the XX/XX/XXXX

UE are unable to provide previous history on this tree at the time of cutting.

If you are a tenant at the above mentioned site address, it is important that the owner of the property be notified about this letter as soon as possible.

If you would like more information of any previous inspections of this tree please call our service providers Select Solutions on (03) 9237 4516 during normal business hours.

Dispute/Complaint Resolution

Under the regulations, UE is the responsible person for the clearing activities identified on this notice and can be contacted if any dispute/complaint cannot be resolved with the UE Service Provider listed above. Disputes or complaints may be lodged using the UE process detailed on the UE website at: https://www.unitedenergy.com.au/contact-us/complaints-compliments/.

We thank you in advance for your co-operation and helping us keep your neighbourhood safe.

https://www.unitedenergy.com.au/contact-us/complaints-compliments/



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19.5 Attachment A.5. - Customer Notification Letter – Important Trees (Sample)



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19.6 Attachment A.6. - Customer Notification Letter–Service Lines (Sample)



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19.7 Attachment A.7 – Current UE Brochures and Advertisements

The “Trees Powerlines and Your Property” is dropped off with every notification letter.

UE Pre- Summer Newspaper Publications and POEL Brochures



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19.8 Attachment A.8 – Example - Newspaper Advertisement:

19.9 Attachment A.9 – Example – ESV Letter Supporting Compliance

NOTICE TO AFFECTED PERSONS OF TREE CUTTING or REMOVAL

United Energy must maintain a minimum clearance space around overhead powerlines in accordance with the requirements of the Electricity Safety (Electric Line Clearance) Regulations 2015 and the Code of Practice for Electric Line Clearance (the Code).

Pursuant to clause 16 of the Code, United Energy hereby notifies affected persons of the cutting or removal of trees on public land in the municipalities of Bayside, Boroondara, Casey, Frankston, Glen Eira, Dandenong, Kingston, Knox, Manningham, Monash, Mornington, Port Philip, Stonnington, and Whitehorse.

The work is scheduled to occur no earlier than 14 days from the date of this notice and no later than 60 days from the date of this notice, and be carried out in accordance with the Code.

Additional information including the precise location and timing of where this work will be undertaken may be obtained from our service provider Select Solutions on (03) 9237 4516.

<<name>> <<address>> <<address>> Dear <<name>>

RE: CLEARANCE OF TREES FROM OVERHEAD ELECTRIC LINES

Under the Electricity Safety Act 1998 and the Electricity Safety (Electric Line Clearance) Regulations 2015, United Energy is required to undertake electric line clearance activities in accordance with the approved electric line clearance management plan.

The purpose of the electric line clearance activities is to prevent vegetation growing too close to electric lines and increasing the risk of electrocution, starting fires or power outages.

The Electricity Safety Act 1998 defines the powers that enable United Energy to fulfil these responsibilities. This includes the power to enter onto and remain on any land, for as long as necessary to complete the work required.

United Energy has identified that urgent works are required on the power line at <<address>>.

Your cooperation in facilitating access to this power line is encouraged as preventing this work will increase the risk of electrocution, starting fires and the power outages.

Should you have any enquiries regarding this matter please contact the designated United Energy representative on xxxx xxxx or at [email protected].

Yours sincerely <<name>> <<title>>



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19.10 Attachment B.1 – Copy of Schedule 2 Code of Practice for Electric Line Clearance

The following Figures determine the methods to be utilised by the VSP to determine the minimum vegetation clearance space to be maintained throughout the vegetation cycle. Re-growth allowances need to be taken into account.

FIGURE 1—PLAN VIEW OF ELECTRIC LINES IN ALL AREAS

Clauses 24, 25, 26, 27, 28 and 29,

Graphs 1, 2, 3, 4, 5 and 6

FIGURE 2—INSULATED ELECTRIC LINES IN ALL AREAS

Clause 24, Graph 1

NOT TO SCALE



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FIGURE 3—INSULATED ELECTRIC LINES IN ALL AREAS AND UNINSULATED HIGH

VOLTAGE ELECTRIC LINES (OTHER THAN 66 000 VOLT ELECTRIC LINES) IN LOW

BUSHFIRE RISK AREAS

Clauses 24 and 26, Graphs 1 and 3

NOT TO SCALE

FIGURE 4—UNINSULATED LOW VOLTAGE ELECTRIC LINE IN A LOW BUSHFIRE RISK

AREA

Clause 25, Graph 2



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FIGURE 5—UNINSULATED 66 000 VOLT ELECTRIC LINE IN A LOW BUSHFIRE RISK AREA

AND UNINSULATED ELECTRIC LINE IN A HAZARDOUS BUSHFIRE RISK AREA

Clauses 27, 28 and 29, Graphs 4, 5 and 6



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19.11 Attachment B.2 – United Energy Applicable Distance Charts

(To Satisfy Schedule 2 Code of Practice for Electric Line Clearance)

The following graphs have been developed to enable the VSP to determine the minimum vegetation clearance space. An allowance for re-growth needs to be added to these distances to determine the actual cutting distance.

GRAPH 1—INSULATED ELECTRIC LINES IN ALL AREAS

GRAPH 2—UNINSULATED LOW VOLTAGE ELECTRIC LINE IN LOW BUSHFIRE RISK AREA

Clauses 3 and 25



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GRAPH 3—UNINSULATED HIGH VOLTAGE ELECTRIC LINE (OTHER THAN A 66 000 VOLT

ELECTRIC LINE) IN LOW BUSHFIRE RISK AREA

Clauses 3 and 26

GRAPH 4—UNINSULATED 66 000 VOLT ELECTRIC LINE IN LOW BUSHFIRE RISK AREA



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GRAPH 5.1 —UNINSULATED LOW VOLTAGE AND HIGH VOLTAGE ELECTRIC LINE (OTHER

THAN A 66 000 VOLT ELECTRIC LINE) IN HAZARDOUS BUSHFIRE RISK AREA

GRAPH 5.2 —UNINSULATED, STEEL HIGH VOLTAGE ELECTRIC LINE (OTHER THAN A 66 000

VOLT ELECTRIC LINE) IN ALL AREAS



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GRAPH 6—UNINSULATED 66 000 VOLT ELECTRIC LINE IN HAZARDOUS BUSHFIRE RISK

AREA

Clauses 3 and 29

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ELECTRIC LINE CLEARANCE MANAGEMENT PLAN 2017/18 · 2017-10-05 · electric line clearance management plan 2017/18 document number: ue pl 0010 version 5.0 – september 2017 page 2