448. This account includes the cost of labour, materials used and expenses incurred in operation and maintenance of plant specifically related to the control of trees, brush and general vegetation which may affect the safe and reliable operation of the transmission system. As well as managing the physical aspects of the right-of-ways such as access trails, culverts, water crossings, approaches, fences & gates, and erosion control.
449. A key driver of current and future vegetation and right-of-way management expenses is the Alberta Electrical Utility Code (AEUC) and the Alberta Reliability Standards (FAC-003-AB). To comply with these standards and practices, but more importantly to maintain a safe and reliable transmission system, AltaLink must maintain specified clearances to any vegetation under or alongside the transmission lines. In order to do this, AltaLink patrols and inspects each line on a
scheduled base, records its findings, and develops a Vegetation Management (VM) Plan. AltaLink implements completed VM plans, records its findings, and audits the results.
Adjustments to the plan are made based on actual vegetation growth through the year as well as actual expenditure variations due to terrain and local conditions.
450. AltaLink’s goal is to achieve and sustain an optimized cost VM program by employing the most cost effective vegetation management practices while complying with all necessary rules and regulations while maintaining relations with all landowners and stakeholders.
Labour:
• contract management and supervision of multiple contract crews assigned to vegetation maintenance duties;
• contract management and supervision of multiple contract crews assigned to Right-of-way (ROW) maintenance duties;
• maintenance and tracking within established programs for management of Reliability requirements;
• Transmission Vegetation Management Program (TVMP), Wildfire Management Program; • contract labour associated with trimming, removing / slashing, mowing of trees and brush; • AltaLink utilizes five main contractors involving approximately 12 active contract crews
depending on time of year. This is expanded as required;
• contract labour associated with the application of herbicides to control weeds in or around substations, switching cubicles or other underground devices;
• AltaLink utilizes one main contractor involving approximately 4 contractor crews to complete this work;
• chemical treatment of right-of-way areas, other than the initial application occurring as a result of construction of line;
• AltaLink utilizes one main contractor involving approximately 4 crews to complete this work. • contract labour associated with the application of herbicides to control brush or noxious
weeds;
• AltaLink utilizes one main contractor and various local resources to complete this work as required;
• contract labour associated grass mowing, snow removal and general maintenance along urban rights of ways; and
• AltaLink utilizes two main contractors and local resources to complete this work as required. Expenses:
• system record and report forms associated with vegetation and ROW management; • meals, traveling and incidental expenses; and
• materials used in vegetation management (VM).
451. AltaLink’s VM expenses are forecasted at $6.5M in 2013 and $7.0M in 2014. The details of which are shown in Table 5.2.10-1 and by volume of activities in Table 5.2.10-3.
Table 5.2.10-1 - USA 571.1 - Operation & Maintenance of Vegetation Management ($M) Expense 2010 Actual 2011 Actual 2012 Mgmt Update 2013 Forecast 2014 Forecast Labour 0.2 0.2 0.2 0.2 0.3 Contracted Manpower 5.9 6.0 6.0 6.2 6.5 Other (GOE) 0.0 0.0 0.1 0.1 0.1 Total 6.2 6.2 6.2 6.5 7.0
Note: Program Management, patrolling and consenting expenses are included in Labour and Contracted Manpower; totals may not add due to rounding.
Table 5.2.10-2 - USA 571.1 - Operation & Maintenance of Vegetation Management Forecast Increase ($M) Forecast Increase 2013 Forecast 2014 Forecast Average Labour 0.1 0.1 0.1 Contracted Manpower 0.2 0.3 0.3 Other (GOE) 0.0 0.0 0.0 Total 0.3 0.5 0.4
Totals may not add to due to rounding
452. VM expenditures are made up of internal AltaLink labour, which includes managing the VM program, patrolling and some landowner consenting activities; external contracted manpower which includes Brushing (mechanical and herbicide) and Right-of-Way (substation and ROW weed control, ROW clean up and urban grass mowing and snow removal) maintenance activities, along with additional external contractors that assist with consenting requirements and General Operating Expenses (GOE) which support overall activities.
Table 5.2.10-3 – USA 571.1 – Operation & Maintenance of Vegetation Management Volumes and Costs – All In
2011 (Actual) 2012 (Mgmt Update) 2013 (Forecast) 2014 (Forecast)
m2 (000's) Unit Cost ($/m2) M $ m 2 Unit Cost ($/m2) (000's) $ M m2 Unit Cost ($/m2) (000's) $ M m2 Unit Cost ($/m2) (000's) $ M Trim 190 2.32 0.4 172 2.32 0.4 207 2.32 0.5 222 2.48 0.6 Slash 440 3.51 1.5 427 3.51 1.5 438 3.51 1.6 479 3.76 1.8 Mow 4,200 0.48 2.0 3,958 0.48 1.9 3,877 0.48 1.9 3,765 0.50 1.9 Spray 7,240 0.16 1.2 9,375 0.16 1.5 8,824 0.16 1.5 9,994 0.18 1.8 Other R/W management, Substations,
Telecommunication N/A 1.0 N/A 1.0 N/A 1.0 N/A 1.0
Total 12,058 0.42 6.2 13,933 0.45 6.2 13,347 0.49 6.5 14,459 0.48 7.0
Totals may not add due to rounding
453. The VM workload forecast is based on the same methodology used in the VM report by Ecological Solutions Inc. (ESI) as filed in AltaLink’s 2007-2008 GTA and updated in the previous tariff application (2011 – 2013 GTA). In the 2007-2008 GTA, AltaLink proposed a nine year VM re-investment schedule which would achieve a stable and sustainable VM program. This proposed schedule and required funding was approved by the EUB and has been subsequently implemented by AltaLink.
454. The forecasts are estimates based on the best information available and average costs. Much of the forecast volume is derived from aerial line patrols and while experienced patrollers reduce the extent of forecast inaccuracy, it cannot be totally eliminated. Secondly, environmental conditions are highly variable and this variability impacts site access and also affects tree growth, tree mortality and pest infestations. When conditions change costs or necessitate work plan modifications, then the volume of work that can be done is altered.
455. AltaLink can report that the actual investment and work completed is tracking closely to the proposed plan and remains on track to achieve the sustainable VM Program by the end of 2015, as shown in Figure 5.2.10-1, and as documented in the latest ESI report, Vegetation
Management Program Update Summary, found in Appendix 15.2 of this Application. A change from the previous reports is that the sustainable amount required past 2015 has increased to address the new facilities coming on stream.
456. AltaLink has entered a period of growth in both transmission lines and substation sites. The effect of these new facilities will begin to increase the VM workload at the end of this test period. The increased facilities will increase the annual workload volume increment (AVI). The net effect will be flat or slightly increasing VM expenditure into future years as the investment to address a larger VM program due to a growing transmission system.
Figure 5.2.10-1 – Minimum Expenditure to Achieve Stable VM Program (Direct Brushing Costs)
457. As noted in the latest ESI report, there is a concern with the appearance of the mountain pine bark beetle in Alberta and the discovery of some affected trees along AltaLink’s transmission lines. It is expected that in as little as five years trees so infected will become a hazard to the transmission lines. AltaLink is identifying the affected areas and collaborating with industry experts and Parks Canada to develop a plan to address this risk. AltaLink has benefited from the fact that Alberta Sustainable Resources Development has been very aggressive in identifying and removing bark beetle infested trees on provincial crown lands. On federal lands, the response has been the opposite: to let nature take its course. There has been some work to coordinate efforts with fire prevention (prescribed burns) and the bark beetle in the Green Zone on both federal and provincial lands. Depending on the spread of the beetles there may be a significant increase in budget requirements to handle this situation in the next GTA test period. 458. It was previously stated that the number of hot spots or priority sites was impeding the cost
effectiveness of the VM program and increasing the risk of tree caused interruptions. The recent level of VM investment in which the VM control activities have exceeded the AVI has reversed the trend of increasing number of priority sites (Figures 5.2.10-2 and 5.2.10-3). The projected ‘pink’ line shows the trend in priority sites prior to the intervention, which began on a modest scale in 2005. The pink exponential line shows what the trend for priority sites would be, should spending fall below the value of the AVI. If AltaLink continues to invest at AVI as AltaLink has forecast in this test period, AltaLink will avoid repeating the 2006 experience. The actual trend line (orange) indicates the VM program has now been shifted to the early stages of a sustainable least cost program.
$0.00 $1.00 $2.00 $3.00 $4.00 $5.00 $6.00 (000, 000) Year
Figure 5.2.10-2 – USA 571.1 Priority Sites as Per Fall Air Patrols Since 2000
Figure 5.2.10-3 – USA 571.1 Priority Sites Identified as per Fall Air Patrols – 2005 to 2012
459. Overall ESI’s review, included in Appendix 15.2 confirms that AltaLink has been successful in implementing the VM recommendations and that the recommendations are now part of AltaLink’s VM Program including expenditure forecasting.
Labour
460. AltaLink internal labour activities focus on maintaining the VM program, performing audits of work and contract crews and monitoring compliance, as well as assisting with standards and quality control on the new assets being constructed. AltaLink historically has had one Vegetation Management Coordinator (VMC) looking after the overall VM programs, management of
contractors, audits of work and monitoring of compliance. 0 200 400 600 800 1000 1200 1400 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 N um beer o f S it es
Table 5.2.10-4 - USA 571.1 Operation & Maintenance Vegetation Management Labour Expense Additions ($M)
Forecast Increase 2013 Forecast 2014 Forecast Average Inflation 0.0 0.0 0.0 Other 0.0 0.1 0.1 Total 0.1 0.1 0.1
461. AltaLink has reviewed the current forecasted workloads and work processes for the test period based on the VM Plan forecasts and anticipated asset growth and confirmed current FTE along with the following proposed additional Vegetation Management Specialists (VMS) in 2013 and in 2014 are required.
462. AltaLink’s complement and forecast of FTEs in USA Account 571.1 is shown in the following tables.
Table 5.2.10-5 - USA 571.1 - Operation & Maintenance of Vegetation FTEs 2010 Actual 2011 Actual 2012 Mgmt Update 2013 Forecast 2014 Forecast Total Year End
FTEs 1 1 1 2 3
Table 5.2.10-6 - USA 571.1 - Operation & Maintenance of Vegetation FTE Additions 2013 Forecast 2014 Forecast Total Vegetation Management Specialist 1 1 2 Total 1 1 2
463. The FTE increases arise from two drivers: increased audit, work tracking and supervision requirements to assure compliance within the enforcement of the new Alberta Reliability Standard FAC-003-AB as well as the increasing number of assets to be maintained.
464. AltaLink recently completed a compliance audit by the AESO on its Vegetation Management program. Based on the detailed and comprehensive evidentiary requests and the work monitoring and qualifications expectations defined in the standard and confirmed by the audit AltaLink needs to increase its supervision and monitoring of the program in order to sustain compliance.
465. Having only one qualified internal program management FTE is not sustainable. If the current employee were to leave AltaLink there would be no qualified field supervision available for the VM program.
466. AltaLink is committed to remaining in compliance with the Alberta Reliability Standards as the minimum requirement set out by the AESO in the interests of power system reliability.
467. AltaLink will be adding a number of new assets over the test period. This is summarized in Table 5.2.7-6 USA 566 – AltaLink Major Assets Volume. The line length increases have been estimated to add approximately 6,500,000 m2
468. The Vegetation Management Specialist positions are responsible to assist in the management of vegetation maintenance on rights-of-ways, access trails; weed control within substations, substation perimeters and city rights-of-ways in order to support the viability, integrity and safety of the transmission system. Job responsibilities would include:
of right-of-way area to be managed over the test period. This represents an estimated 15% increase in the amount of vegetation and rights of way to be managed and maintained.
• perform field audits of vegetation management contractor crews and work sites for safety, quality control, environmental compliance and accuracy of Transmission Vegetation Management Program (TVMP);
• perform patrols by air or ground and record the results and operational concerns, prioritize, assess risk and make recommendations for repair, maintenance or upgrades to transmission rights-of-ways for both vegetation and access;
• assist in the emergency repair of the Transmission System, through ground or air patrols to determine extent of damage;
• consenting and landowner notifications for right-of-way maintenance operations obtaining appropriate permits and letters of authorization on public lands;
• assist with acceptance of new transmission facilities in preliminary review of design, during and after construction, with regards to vegetation standards, quality control and future maintainability;
• assist in updating maintenance plans and schedules for new and existing facilities;
• assist in the development of standards and procedures to support vegetation maintenance; and
• assist in research, evaluation and recommend new tools, test equipment, materials and practices.
Contracted Manpower (Including Brushing)
Table 5.2.10-7 – USA 571.1 Operation & Maintenance of Vegetation Management Contract Manpower Forecast Increase ($M)
Forecast Increase 2013 Forecast 2014 Forecast Average Inflation 0.3 0.3 0.3 Other (0.1) 0.0 0.0 Total 0.2 0.3 0.3
Totals may not add to due to rounding
469. The $0.3M per year average increase in contract manpower expenses is attributable to AltaLink’s inflation assumptions that are discussed in Section 1.8 Forecasting Methodology. 470. At the highest level, the VM contracted manpower forecast is made up of two distinct
categories based on the type of work performed in the management of AltaLink’s Rights-of-Way (ROW).
471. The first category, “Brushing”, is work associated with the actual control methods done to manage the vegetation on AltaLink’s ROW, typically outside the urban areas. This work includes: • spraying, herbicide application, for control of trees / brushes under the wires and on the
ROW;
• mowing, mechanical removal of vegetation;
• removing (slash or removal) of trees where the use of mechanical mowers is not possible or economic (side hills, small sections, shelter belts); and
• trimming, where the complete removal is not possible due to landowner concerns.
472. The forecast for the brushing is based on the volume of work as estimated from aerial patrols of the ROWs and the workload liability. The workload liability is the accumulated brushing
inventory due to a deficit between annual vegetation growth and the annual control activities in the previous years. The status of the workload liability is discussed further below and is
quantified in Table 5.2.10-8.
473. The second category “Other” is work associated with the management of the overall VM program, ROW management through urban areas as well as the substation and radio sites. Activities consist of substation and ROW weed control, grass mowing and snow removal, ROW cleanup and the patrolling, site inspections, auditing, and landowner consenting and
notifications required for the complete VM program.
474. Landowner consenting refers to the activities that need to be completed in advance of the brushing and ROW control activities. Specifically, consenting includes:
• confirming the area that needs to be managed or trees that need to be trimmed or removed by examining the specific site;
• drafting a sketch that is given to the landowner and to the brushing contractor as a part of the construction execution package;
• confirming the brushing work schedule as well as outlining how ROW are to be accessed, including addressing any landowner concerns;
• obtaining landowner permission to access their lands; and • obtaining permits for off ROW access and pipeline crossings.
475. There are no fees paid to the landowner for these maintenance activities, rather the consenting costs reflect labour in the execution of the consenting/notification process.
476. Consenting is generally done by contractors due to the requirements to work odd hours to meet the landowners’ schedules. There is a large amount of evening and weekend hours required as well as specialized knowledge, history and relationships with regional landowners.
477. The overall VM contracted manpower forecast for the test period is driven by the volume of work identified through the annual aerial patrols and the transmission line maintenance information system.
Table 5.2.10-8 – USA 571.1 Contracted Manpower - Volume of Work by Work Type (m2 Activity ) 2011 Actual 2012 Mgmt Update 2013 Forecast 2014 Forecast Trim 190,000 172,000 207,000 222,000 Mow 4,200,000 3,958,000 3,877,000 3,765,000 Slash/Remove 440,000 427,000 438,000 479,000 Herbicide 7,240,000 9,375,000 8,824,000 9,994,000 Total 12,058,000 13,933,000 13,347,000 14,459,000 Brushing Cost $4.5M $4.5M $4.5M $4.9M Other Contractor costs $1.5M $1.5M $1.7M $1.7M Total Contracted Manpower Costs $6.0M $6.0M $6.2M $6.5M
Other R/W management contractor costs include Consenting, Substation Weed Control and R/W Clean Up
479. As outlined in the original report, in order to reach and maintain a sustainable VM program, the annual VM program investment must exceed the Annual Workload Volume Increase (AVI), i.e. the annual vegetation growth.
480. Table 5.2.10-9 shows the historical difference between the brush inventory value and the brush component of VM expenditures. Expenditures have exceeded the value of the Annual Workload Volume Increment (AVI); AVI is the incremental amount of vegetation growth in the period between annual VM control activities, measured on an annual basis since 2005. The positive result is seen in the decreasing value of the unrecognized liability bringing the unrecognized liability to zero in 2010.
481. The Unrecognized Liability has remained at zero since 2010. This is a positive indicator that the continued maintenance investment and the forecast investment over the test period will continue to be sufficient to address the required VM control activities sustaining a stable long- term VM program.
482. The increased investment in the VM program since 2006 has allowed AltaLink a consistent go forward focus on the cost effective practices of herbicide application and mowing versus the reactive practice of hot spotting. The gain available in the reduction of the average per hectare cost has been realized and is reflected in Table 5.2.10-3.
Table 5.2.10-9 - Workload Liability – Brushing ($M)
2006 2007 2008 2009 2010
Brush Inventory 8.2 7.8 6.0 6.0 4.6
Expenditures (brush) 3.2 3.9 4.9 5.4 5.3
Unrecognized Liability 5.0 3.8 1.2 0.6 0.0
483. The continuation of the nine year re-investment schedule is still recommended. It provides for the best fit for maintenance cycles based on re-growth rates (average pruning cycles are three years, removal are nine years). The schedule maximizes the efficiencies associated with labour and equipment available in the market. It levels the re-investment requirements over a longer period, while still managing the risk associated with workload liability removal.
Other (GOE)
Table 5.2.10-10 – USA 571.1 Operation & Maintenance of Vegetation Management GOE Forecast Increase ($M)
Forecast Increase 2013 Forecast 2014 Forecast Average Inflation 0.0 0.0 0.0 Other 0.0 0.0 0.0 Total 0.0 0.0 0.0
Totals may not add to due to rounding
484. All increases in the GOE category are due to inflation which are materially less than $0.1M in total for each of forecast years, as shown Table 5.2.10-10 above.
485. This category is mostly comprised of meal and hotel expenses, land rights, damage claims, permits, access fees and a small amount of materials in support of VM activities.