Submission on Ausgrid s proposed vegetation management/tree pruning service charter

Transcription

1 Submissin n Ausgrid s prpsed vegetatin management/tree pruning service charter Prvided t: Ausgrid Vegetatin Management Wrking Grup and Ausgrid Made by lcal gvernment representatives n the Ausgrid Vegetatin Management Wrking Grup frm the fllwing rganisatins/cuncils: LGNSW representing cuncils in NSW Lcal Gvernment Tree Resurces Assciatin Sutherland Shire Cuncil Parramatta City Cuncil Willughby Cuncil Sydney City Cuncil Ku-Ring-Gai Municipal Cuncil Inner West Cuncil Strathfield Cuncil Burwd Cuncil Lake Macquarie City Cuncil Newcastle City Cuncil Canterbury-Bankstwn City Cuncil Wllahra Municipal Cuncil Msman Cuncil Randwick City Cuncil Nrth Sydney Cuncil Nrthern Beaches Cuncil 15 February 2017

2 A better service charter LGNSW and cuncils represented n the Ausgrid Vegetatin Management Wrking Grup d nt supprt Ausgrid s draft vegetatin management/tree pruning service charter as currently prpsed t the Ausgrid Vegetatin Management Wrking Grup (appendix A). This submissin utlines the changes we seek. The purpse f the submissin is t fllw up n LGNSW s letter t Ausgrid s COO, Trevr Armstrng f 25 January 2017 (appendix B) and prvide mre detail n ur cncerns ver, and requests fr imprvement f, the prpsed service charter. We d nt believe the charter strikes the right balance between prtecting the safety and reliability f the electricity netwrk and prtecting the imprtant urban amenity and ecsystem functins prvided by trees and urban vegetatin. This will be f increasing imprtance given the scale f husing grwth planned acrss Ausgrid s netwrk area in the cntext f the NSW Gvernment s widespread planning refrms. We are cncerned that the current draft service charter will nt achieve Ausgrid s bjective t imprve vegetatin management and cuncil engagement. It will nt address the real issue f cuncils, which is that Ausgrid s tree pruning practices are excessive and d nt achieve satisfactry tree management utcmes. A service charter that is vluntary and des nt include specific and enfrceable service levels with respect t the extent and frequency f pruning is unlikely t achieve satisfactry utcmes. We believe that the regulatry regime needs t: Include prtecting urban amenity and ecsystem functins prvided by trees and urban vegetatin as an bjective; and Ensure, by way f enfrceable service standards, that electricity distributin netwrk service prviders: Take int accunt urban amenity bjectives and avid excessive and harmful pruning; Cmply with relevant vegetatin management standards: Cnsult and agree with cuncils n activities prir t undertaking them: and Pursue alternative ptins such as aerial bundling r undergrund cabling where feasible. We request that the prpsed service charter be strengthened t include specific and enfrceable service standards including: Minimum service standards Adherence t maximum regrwth pruning allwances fr individual tree species acrss Ausgrid s netwrk area. These shuld be develped in cnsultatin with lcal gvernment and ther relevant stakehlders. Currently, the Electricity Industry Safety Steering Cmmittee s Guide fr the Management f Vegetatin in the Vicinity f Electricity Assets, (2016) is heavily fcused n achieving infrastructure and peratinal safety utcmes and nly prescribes minimum clearing requirements. It des nt prtect against excessive pruning.

3 Cmpliance in all vegetatin management/tree pruning activities undertaken by Ausgrid with the Australian Standard AS , Pruning f Amenity Trees and the Electricity Industry Safety Steering Cmmittee s Guide fr the Management f Vegetatin in the Vicinity f Electricity Assets (2016). This includes ensuring that n-site peratrs that carry ut vegetatin management/tree pruning activities are apprpriately qualified and equipped t carry ut such activities (e.g. the Australian Standard AS , Pruning f Amenity Trees requires that at least ne peratr n site is qualified under Certificate II in Arbriculture). Service agreement with cuncil Befre Ausgrid can undertake regular vegetatin management/tree pruning activities in a cuncil area, Ausgrid and the cuncil need t enter int an agreement that sets ut agreed service levels fr the planned vegetatin management/tree pruning activities and the charter shuld require this. The service agreement shuld be based n a dcumented prcess by which cuncil and Ausgrid assess, and agree n, apprpriate vegetatin management actins and pruning levels fr any particular area, tree, r grups f trees. This prcess wuld prduce a reprt available t bth parties against which actual perfrmance f vegetatin management/tree pruning can be measured. The service agreement shuld include: Clarity regarding apprpriate pruning levels including hw the Australian Standard AS , Pruning f Amenity Trees is interpreted and applied (particularly t avid misuse f the standard) and hw maximum regrwth pruning allwances are applied. A requirement fr individual risk assessments fr trees t alter minimum clearance and ther requirements under the Electricity Industry Safety Steering Cmmittee s Guide fr the Management f Vegetatin in the Vicinity f Electricity Assets, (2016); e.g. fr branches that can remain (i.e. branches within minimum vegetatin clearance that pse limited r n risk t pwer lines). Qualificatin requirements fr n-site peratrs including stating hw any requirements f the Australian Standard AS , Pruning f Amenity Trees are applied. The prductin f tree management plans where required under the Electricity Supply (Safety and Netwrk Management) Regulatin (NSW) 2014, including develping agreed alternative slutins t tree pruning t achieve mre balanced recgnitin f urban amenity, as well as netwrk safety and reliability. A mandatry cmmunicatin plan t clearly and cmprehensively infrm the cmmunity abut the upcming vegetatin management/tree pruning activities including: Public exhibitin f service agreement by Ausgrid. Prvisin f adequate ntificatin t the cmmunity (e.g. brad infrmatin f upcming activities, a reasnable time befre activities Page 3 f 9

4 start; ntificatin f individuals immediately befre activity will affect them). Cuncils being included in these ntificatins. Clear identificatin that vehicles and equipment used by Ausgrid cntractrs fr Ausgrid s vegetatin management/tree pruning activities are undertaking wrk fr Ausgrid (e.g. similar t the A-Frame signs used by Ausgrid cntractrs undertaking cable upgrades in lcal streets). An independent dispute reslutin prcess t arbitrate where agreement cannt be reached. Perfrmance reprting, audit, cmpliance and enfrcement Ausgrid shuld reprt n perfrmance f, and cmpliance with, minimum service standards as abve and service levels agreed in the individual service agreements with cuncils. This data culd be made available t cuncils and via Ausgrid s Data t Share website. Where necessary, the reprting shuld be independently assessed/audited t ensure rbustness f infrmatin and address any cnflicts f interest. A meaningful penalty regime must be established fr nn-cmpliance with minimum service standards and service levels agreed in the individual service agreements. This needs t include an independent dispute reslutin prcess fr cuncils and Ausgrid where disputes ver utcmes r perfrmance/cmpliance need t be reslved. T ensure penalties are effective, Ausgrid must nt be allwed t recver any penalties frm custmers via regulated prices. Strategic assessment f alternatives A cmprehensive (and mre strategic) prcess f cnsidering alternatives t tree pruning including aerial cable bundling/prtectin, undergrund cabling (fr new develpment), remval and replacement f trees and ther vegetatin management alternatives such as species selectin must be implemented. Existing prcesses fr cuncils t request aerial bundled cabling (ABC) r the remval and replacement f trees, including cnsideratins f design, cst, cst sharing and financing ptins, need t be streamlined and made mre transparent. Ausgrid s prcesses are nt custmer fcussed and create a barrier fr alternative slutins t be a viable ptin fr cuncils; e.g. t get cuncil-funded ABC prjects up and running. N-G Zne Existing prcesses and practices fr cuncils t have tree pruning/management wrk undertaken in the electricity netwrk prvider s N-G Zne need t be mre efficient. They currently cause undue additinal administratin and peratinal csts, and significant delays ccur in Ausgrid s authrisatin. Price guging by Ausgrid s nminated and authrised cntractrs must als stp. The issue f N-G Znes was parked by Ausgrid s wrking grup facilitatrs, and this issue has nt been revisited, despite being f critical imprtance t cuncils. Page 4 f 9

5 T imprve the prcess fr tree pruning in the N-G Zne, Ausgrid and cuncils shuld agree t the fllwing: Ausgrid t prvide a list f multiple tree pruning cntractrs that cuncils can use fr any wrk within, r wrk that requires access thrugh, the N-G Zne in their cuncil area. If cuncil uses a cntractr frm the list, cuncil shuld nt be required t cnsult with, and btain written apprval frm, Ausgrid (the netwrk peratr) t undertake the wrk pursuant t sectin 3.5 f the WrkCver NSW, Wrk Near Overhead Pwer Lines - Cde f Practice (2006). Ausgrid will ensure that cntractrs n the list are apprpriately qualified and equipped t undertake wrk in the N-G Zne. Ausgrid agrees t carry an apprpriate share f the cst f the tree pruning wrk in the N-G Zne where the wrk was (partly) necessary t prtect the safety f electricity assets. Cuncils will ntify Ausgrid f any wrk t be carried ut in the N-G Zne prir t cmmencing the wrk and will maintain a recrd f any N-G Zne wrk. It is acknwledged that implementing this regime might require changes t the WrkCver NSW, Wrk Near Overhead Pwer Lines - Cde f Practice, (2006). Cuncils and Ausgrid shuld wrk tgether t prmte such change. Cnclusin LGNSW, the Lcal Gvernment Tree Resurces Assciatin, and cuncils represented n the Ausgrid Vegetatin Management Wrking Grup d nt supprt Ausgrid s draft vegetatin management/tree pruning service charter as currently prpsed t the Ausgrid Vegetatin Management Wrking Grup. We acknwledge that the prpsed vluntary service charter utlines, in writing, the brad principles by which Ausgrid engages the cmmunity and cuncils regarding tree trimming. This is an imprtant first step twards meaningful engagement with cuncils n the real issues f cncern, which are Ausgrid s tree pruning prcesses and practices. LGNSW, the Lcal Gvernment Tree Resurces Assciatin and cuncils represented n the Ausgrid Vegetatin Management Wrking Grup seek Ausgrid s respnse t ur cncerns ver, and requests fr imprvement f, Ausgrid s draft vegetatin management/tree pruning service charter as part f Ausgrid s cmmitment t engage with cuncils in a transparent and meaningful way. LGNSW, the Lcal Gvernment Tree Resurces Assciatin, and cuncils are still hpeful f, and cmmitted t, wrking with Ausgrid t develp a mre balanced apprach t tree pruning/vegetatin management in lcal streets. Page 5 f 9

6 APPENDIX A Page 6 f 9

7 Page 7 f 9

8 APPENDIX B Page 8 f 9

9 Page 9 f 9