Authors: Marc Sherman & Dwayne Stradford | June 19, 2025

Best Practices to Reduce the Risk of Outages

One year into enforcement of FAC-003-5, utilities are rethinking right-of-way strategies to stay compliant and protect grid reliability. With the retirement of Requirement R2 and removal of interconnection reliability operating limits (IROL), all FAC-003-5 circuits now fall under Requirement R1. These changes carry significant implications for vegetation management programs, which must now ensure documentation and compliance practices are aligned with the revised standard to avoid mounting risks and massive fines. 

In our latest NERC Compliance Conversation Dwayne Stradford, TRC’s NERC Compliance Director and Marc Sherman, Vegetation Project Manager, explore why proactive vegetation strategies are now mission-critical and how utilities can turn compliance into a long-term resilience advantage. 

The Historic Shift to FAC-003-5

When the 2003 blackout occurred, vegetation was at the heart of the crisis. Today, that risk remains and it’s growing. Summer is underway. Trees are growing. Storms are coming. Climate conditions are less predictable, and the consequences of inaction are steep: up to $1 million a day in potential fines and the risk of widespread outages. 

But meeting FAC-003-5 requirements isn’t about checking boxes on a calendar. As our experts emphasize, nature doesn’t operate on a schedule. An effective vegetation management program must be situationally aware and tailored not only to the right-of-way, but also to the species, soil conditions, terrain and even community dynamics that define it. 

Take yellow poplars in Michigan, for example. Beautiful trees, but shallow-rooted and vulnerable to wind events. Recognizing these nuances can be the difference between a reliable corridor and a future incident report. 

Why Integration Is Everything

One of the most compelling themes from the conversation is the value of integration. Too often, vegetation management is siloed and consequently looped in only after design decisions are made or maintenance is underway. This reactive approach puts teams behind the curve. 

Bringing vegetation experts into the room early, during engineering meetings, rebuild planning or new construction creates natural opportunities to align strategies. It’s how vegetation teams can “piggyback” on other field access efforts to address hard-to-reach areas and reduce duplication. It’s also how they can build trust with landowners whose cooperation is critical to ongoing access. 

The key, our experts share, is consistent dialogue. From field teams to compliance leads, a shared understanding of what’s upstream and downstream of each project strengthens every touchpoint. When storm season hits or rebuild schedules shift, everyone’s already aligned. 

Technology and Transparency: Tools That Drive Excellence 

Technology is changing the game. Satellite imagery, LiDAR and analytics aren’t just nice-to-haves, they’re essential tools for managing large, heavily wooded service areas and agricultural corridors alike. 

In regions like Iowa and southern Minnesota, geography allows for longer corridors with fewer interruptions. Contrast that with the dense tree canopies of Northern Ohio or Michigan, and the need for adaptability becomes key to build into every plan. Tools like Governance, Risk and Compliance (GRC) platforms give teams the ability to set clear timelines, track obligations, and improve visibility across departments. 

Although no tool replaces the need for ownership. Every program needs an author; someone accountable for ensuring decisions are documented, internal controls are followed, and lessons learned are shared. That ownership leads to consistency, which leads to audit readiness. 

Embedding a Culture of Vigilance 

The best vegetation management programs are embedded into a utility’s culture, not tacked on. That culture is built through informal learning moments, like brown bag lunches, and through the empowerment of field staff to act on what they see. 

It’s also about recognizing that audit success isn’t a deadline, it’s a byproduct of doing the work correctly, every day. Keeping documentation updated, processes current and tools connected to real-world outcomes ensures that when auditors do arrive, your team is already ahead. 

Adaptability Today Means Resilience Tomorrow

With the pace of transmission infrastructure development accelerating, vegetation management isn’t just a regulatory concern; it’s a grid resilience strategy. As new infrastructure is added, new risks emerge. The more proactive utilities are in addressing them, the more confident they can be in their system’s reliability. 

At TRC, we bring a grounded, integrated approach to vegetation management. Our teams understand not just the standards, but the operational reality behind them. We help clients navigate that complexity with evidence-based resources, forward-thinking strategy and practical insight. 

Ready to get started? 

Strengthen your vegetation program and reduce risk across your system.

Contact us

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Marc-Sherman
Marc Sherman

Currently serving as Project Manager at TRC Companies, Marc leads vegetation management efforts for utility-scale solar and energy storage sites, integrating sustainability and reliability targets into Operations & Maintenance (O&M) programs. He has over 25 years of experience in transmission and renewable energy projects. As an ISA Certified Arborist, he has successfully managed multi-million-dollar vegetation maintenance programs across diverse terrains and regulatory environments, ensuring safety, compliance and operational efficiency. His expertise spans 13,000+ miles of transmission lines across seven states, with a proven track record in environmental stewardship, contractor oversight, and risk mitigation. Marc also has experience managing vegetation clearing for high-profile transmission projects, collaborating with regulatory agencies and driving innovative solutions to meet environmental and operational goals. Please contact Marc Sherman for more information.

Dwayne-Stradford-e1750340651571
Dwayne Stradford

Dwayne Stradford serves as TRC’s NERC Compliance Director in the Power Division. He is leading and coordinating TRC’s NERC compliance support services with our various power utility clients. He is an accomplished, diverse energy professional with over 30 years of engineering experience regarding real-time transmission operations, short/long term transmission planning, NERC Reliability Compliance Standards (both NERC-CIP and NERC O&P), Transmission Reliability Assurance, utility scale renewables integration, FERC Regulatory/RTO policy, and Project Management. He spent the bulk of his career (close to two decades) working for AEP but has considerable working experience in the electric utility industry as a professional consultant. He has worked with utility clients on transmission and generation related projects in all three interconnections, so he has breadth of regional BES experience throughout the entire country. Please contact Dwayne Stradford for more information.