Wildfire plans and tree clearing in Utah: the Wildland Fire Planning and Cost Recovery Act and Rocky Mountain Power's plan
What Utah Code chapter 54-24 requires in a utility wildland fire protection plan, how the Public Service Commission of Utah approved the first plan on October 13, 2020, and the tree clearance distances in Rocky Mountain Power's revised 2023 plan.
Checked against the sources at the bottom of this page on October 9, 2026. Rules, fees and pay change: the source has the last word.
This page reports what the official source says. It is not legal advice: ask the office named here. It restates three documents as read on October 9, 2026: Utah Code chapter 54-24 on the Utah Legislature site, the Public Service Commission of Utah order of October 13, 2020 in docket 20-035-28, and the revised 2023 plan that Rocky Mountain Power filed in docket 23-035-44 on February 28, 2024. A fourth document, the comments of the Division of Public Utilities dated May 10, 2024, gives the history of that filing. The side by side with other regions is on the guide to utility wildfire plans and tree clearing.
What the Utah statute requires
Chapter 54-24 is called the Wildland Fire Planning and Cost Recovery Act and took effect on May 12, 2020. Section 54-24-201 says a qualified utility must prepare a wildland fire protection plan. The plan must include, among other items, a description of areas of heightened wildland fire risk, the procedures, standards and time frames for inspecting and operating infrastructure, and "the procedures and standards" the utility will use to perform vegetation management. It must also describe de-energizing power lines and disabling reclosers, restoring the system after a fire, costs, and community outreach.
The first plan was due on or before June 1, 2020, and a new plan is due on or before October 1 of every third year after 2020. An annual report on compliance with the plan is due no later than June 1, 2021, and each year after 2021. The Commission reviews the plan with input from the state Division of Forestry, Fire, and State Lands and must approve it if it is reasonable and in the public interest and appropriately balances the cost of the plan against the risk of a wildland fire. Section 54-24-203 sets a similar content list for an electric cooperative, without the costs and community outreach items, and its plan goes to its own governing authority and then as a filed copy to the Commission.
Section 54-24-303 ties the plan to liability. It limits what a plaintiff can recover from an electrical corporation for a fire claim, but the limits do not apply if the corporation had no plan approved by its governing authority before the fire, or if the Commission finds material noncompliance with the plan in the fire area. The statute does not print a tree clearance distance. Those sit in each utility's own plan.
The 2020 order
The Commission's order of October 13, 2020 says Rocky Mountain Power filed its plan on June 1, 2020, and that the state forestry division filed a letter on August 13, 2020, while the Division of Public Utilities and the Office of Consumer Services filed comments on August 17, 2020. The forestry division said the plan was acceptable. The Office of Consumer Services raised concerns about customer notice of public safety power shutoffs and about whether cost and risk were balanced. The order approved the plan and directed the company to report in its annual reports any updates it made to its wildland fire practices in the year before, with the reason.
The revised 2023 plan
The Division of Public Utilities comments say Rocky Mountain Power filed its 2023 plan on September 25, 2023, and that the state forestry division commented on November 9, 2023 that some risk data used was outdated. The company asked the Commission to vacate the schedule, worked with the forestry division and filed a revised plan on February 28, 2024. The Division of Public Utilities reports the three year cost rose from US$322 million to US$446 million, of which US$372 million is capital. It recommended the Commission acknowledge the revised plan as complying with section 54-24-201.
The revised plan's vegetation chapter says distribution circuits in Utah are generally worked on a planned three year cycle. It says tall growing vegetation is pruned to keep a safe distance from lines, and dead, dying or diseased trees at higher risk of falling into a line are removed. It says the company contracts with vegetation management service providers for pruning and removal on both transmission and distribution lines. Its footnotes name ISA best management practices on pruning and ANSI A300 as the pruning references, and ANSI A300 Part 9 and the ISA tree risk assessment best management practices for the Level 1 and Level 2 assessments of high-risk trees.
Distribution clearances in the plan
The plan sets minimum post-work clearances by how fast the tree grows: slow under 1 foot a year, moderate 1 to 3 feet, fast over 3 feet. The first table is for areas outside the fire high-consequence areas (FHCA), the second for inside them.
| Clearance | Outside FHCA (slow, moderate, fast) | Inside FHCA (slow, moderate, fast) |
|---|---|---|
| Side | 8, 10, 12 feet | 12, 12, 14 feet |
| Under | 10, 12, 14 feet | 12, 14, 16 feet |
| Overhang | 12, 12, 12 feet | 12, 14, 14 feet |
Inside the FHCA the plan adds three strategies: an annual vegetation inspection of all lines, the larger clearances above, and annual pole clearing. It describes pole clearing as removing all vegetation within a 10 foot radius, up to eight feet vertically, around poles with switches, clamps, fuses or other spark-capable devices, and applying herbicide or soil sterilant unless the law or the property owner prohibits it. The plan says this is meant to lower ignition risk if sparks fall, not to prevent contact with a line.
Transmission clearances in the plan
For transmission the plan lists the minimum vegetation clearance distance from the NERC standard FAC-003-4, an action threshold that triggers work, and the minimum clearance after work.
| Line voltage | Minimum clearance / action threshold (feet) | Minimum after work (feet) |
|---|---|---|
| 500 kV | 8.5 / 18.5 | 50 |
| 345 kV | 5.3 / 15.5 | 40 |
| 230 kV | 5.0 / 15.0 | 30 |
| 161 kV | 3.4 / 13.5 | 30 |
| 138 kV | 2.9 / 13.0 | 30 |
| 115 kV | 2.4 / 12.5 | 30 |
| 69 kV | 1.4 / 10.5 | 25 |
| 45 kV | Not applicable / 5 | 20 |
The plan says main grid transmission lines above 200 kV are inspected annually and lines under 200 kV are inspected as needed.
Sources
- Utah Legislature, Utah Code Title 54 Chapter 24, Wildland Fire Planning and Cost Recovery Act, effective May 12, 2020, read October 9, 2026
- Public Service Commission of Utah, order approving Rocky Mountain Power's wildland fire protection plan, docket 20-035-28, October 13, 2020, read October 9, 2026
- Rocky Mountain Power, Revised 2023 Utah Wildland Fire Protection Plan, docket 23-035-44, February 28, 2024, read October 9, 2026
- Utah Division of Public Utilities, comments on the revised 2023 plan, docket 23-035-44, May 10, 2024, read October 9, 2026