Relating to plans for the management and inspection of distribution poles.

Contracts

• Vendor MSAs: You must amend Master Service Agreements with third-party inspection and vegetation management vendors.
• Indemnification: Update clauses to protect the utility if a vendor’s failure to document inspections accurately causes a false PUC filing.
• Data Standards: Mandate that vendors provide inspection data in a format compatible with your May 1 annual reporting requirements.

Hiring/Training

• Plan Administrator: You must designate a specific officer or manager to oversee the plan; this role is statutorily required.
• Certification Workflow: Implement a verification process for all technicians (internal and external). No one touches a pole without documented proof they meet the training standards outlined in your filed plan.

Reporting & Record-Keeping

• Initial Filing: A comprehensive plan detailing scope, objectives, personnel roles, training processes, inspection timelines, and financial estimates.
• Annual Update (May 1): A recurring mandatory report detailing compliance metrics, total costs, specific pole counts, and remediation actions taken.
• Complaint Portal: You must operationalize a distinct tracking mechanism for landowner complaints regarding pole conditions; general customer service tickets are insufficient.

Fees & Costs

• Administrative Overhead: High. Requires dedicated resources for data aggregation and reporting.
• Capital Expenditure: The "Estimated Cost" requirement in the plan may lock you into CapEx projections for pole replacements.
• Penalties: Non-compliance triggers standard PUC administrative penalties under Chapter 15, Utilities Code.