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Regulatory Update

Update to FAC-003-5 Brings Sweeping Changes to Transmission Classifications Starting April 1

Dwayne Stradford | March 21, 2024

Beginning April 1, 2024, the latest version of NERC’s Transmission Vegetation Management reliability standard will be enforceable. FAC-003-5 includes substantial modifications that will require immediate consideration and adaptation by all impacted NERC Registered Transmission Owners and Generator Owners.

Compliance Program Impacts

The first significant impact of this standard update involves the retirement of Requirement R2. Starting on April 1, 2024, all qualified FAC-003-5 transmission circuits will now be categorized under Requirement R1.

In addition, there will no longer be an explicit reference to Interconnection Reliability Operating Limit (IROL) facilities. Instead, the standard points out any overhead transmission line operated below 200 kV, that, if lost would result in instability, cascading outages, or uncontrolled separation of the bulk electric system.

Major Western Electricity Coordinating Council (WECC) Transfer Paths are still called out and referenced in the new version of FAC-003-5. It should be noted that Major WECC Transfer Paths above and below the 200 kV voltage operational threshold are still referenced in the applicability section, as it was in the previous version. In the past, Requirement R1 was reserved for the two critical circuit classifications (IROLs and Major WECC Transfer Paths), with Requirement R2 serving as a catch all for the rest of the circuits over 200-kV. This will no longer be the case, moving forward.

Recommendations and Next Steps

With the current pace of new transmission development, in conjunction with the steady transition to renewable energy resources (wind, solar and battery storage), we foresee potential challenges in maintaining the accuracy of official FAC-003-5 Transmission Vegetation Management inspection schedules. It is advised that all Generator Owners and Transmission Owners collaborate to align and calibrate their FAC-003 Transmission Vegetation Management Plans, maintenance policies, operating procedures and pre-commissioning guidelines. As an example, when new certified FAC-003-5 circuits get approval for construction, there should be an explicit communication with the Vegetation Management team to add this new circuit to their inspection and maintenance lists.

Considering the impending April changes, and retired R2 classification, it is imperative that Transmission Owners and Generator Owners start transitioning all FAC-003-5 circuits over to the Requirement R1 classification. These changes could take significant time and effort to fully implement and could lead to unwanted fines, in the event of an emerging audit or regional entity spot check.

TRC is dedicated to sharing our best FAC-003 Transmission Vegetation Management compliance practices, while being your overall trusted NERC compliance advisor. We have established a multi-tier approach that allows for progressing your overall compliance awareness while enhancing your Audit Readiness posture. Contact us or review our related services to learn more.


NERC 2015-09_FAC-003-5

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TRC closely follows the national, provincial, and state regulatory trends in all regions of North America. Our approach to power system security, engineering, planning, design, construction and commissioning testing, balances solutions that incorporate industry reliability risk trends, mandatory reliability standard requirements, regulatory guidance, compliance obligations, best practices, operational goals, and budgets. With expertise in power system planning, engineering, and operations, TRC supports public utilities and private energy providers in their efforts to stay ahead of the regulatory curve and to meet or exceed regulatory requirements as they evolve.

This regulatory update is provided as a service to TRC’s utility clients, helping to keep you informed of forward-looking issues that will impact your company’s electric system reliability risks along with related topics regarding regulatory developments, to help you achieve your company’s business goals.

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 29 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.

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