PacketUpload · Utility Vegetation

Prove span-level UVM work before audits and discovery.

Post-2018 wildfire litigation rewrote the evidentiary standard for distribution utilities, and NERC FAC-003-5 Category 1 violations still run $1M per violation per day on transmission. PacketUpload turns contractor photos and LiDAR into cited, span-level compliance evidence — so your WMP filings, FAC-003 audits, and discovery requests are answered in hours, not weeks.

Built for VPs of Operations, Wildfire Mitigation leads, and Regulatory counsel at IOUs and G&Ts carrying high-consequence service territory.

$1M
Per violation, per day — the NERC Compliance Monitoring and Enforcement Program maximum penalty for Category 1 transmission FAC-003-5 vegetation-caused outages.
Source: NERC CMEP Sanction Guidelines
$13.5B
PG&E settlement tied to the 2017–2018 Northern California wildfires, where vegetation contact with distribution conductors became the central litigation issue.
Source: CPUC — 2020 PG&E Chapter 11 plan of reorganization
50%+
Share of customer-hour outages on many US distribution utilities attributable to vegetation contact in non-MED weather — the single biggest controllable reliability driver.
Source: EEI / EPRI reliability research
200 kV
The transmission threshold above which NERC FAC-003-5 applies — span-level evidence required at cycle cadence. Distribution lives under state PUC WMP and reliability rules instead.
Source: NERC FAC-003-5 standard

Your compliance defense lives in a stack of photos you’ve never read.

NERC FAC-003-5 penalties run $1M per violation per day, and wildfire litigation across 2017–2020 rewrote the evidentiary standard with multi-billion-dollar settlements. Yet UVM evidence still arrives as zipped folders from Asplundh, Davey, and Lewis crews that nobody reviews at scale — until a plaintiff’s expert does.

NERC FAC-003-5

Missing MVCD evidence = Category 1 violation

Penalties run up to $1M per violation per day. “We did the cycle” is not evidence.

$1M / day
WMP discovery

Wildfire risk hides in your backlog

Deferred trims live in Clearion or Overstory. If it is not discoverable, it is not defensible.

Multi-B settled
Contractor QC

Manual review catches 2% of packets

Hundreds of crews, hundreds of thousands of spans — the rubber stamp is the workflow.

2% reviewed
Deposition standard

“We trusted the contractor” is not a defense

Post-incident review looks at pre-work LiDAR, cycle cadence, and span-level sign-off.

Span-level

Evidence extracted and verified at span-level cycle cadence.

From LiDAR and satellite imagery to drone and ground photos to AAA Z133 arborist notes, our models extract MVCD clearance, species, tree health, work completeness, and risk tier. Compliance stops being a story — it becomes a cited, timestamped, geotagged evidence library. Low-confidence extractions route to your forester with reason codes — the final call stays with your team.

01

MVCD clearance verification from imagery

Our models extract measured clearance distance (feet and meters), species, tree health, encroachment angle, and completeness of work from drone, LiDAR, satellite, and handheld photos. Output aligns to NERC FAC-003-5 MVCD tables and ANSI A300 pruning standards.

02

Pre-/in-/post-work packet completeness in seconds

Every pre-work assessment, in-progress crew photo, and post-work sign-off cross-referenced against your UVM plan — span by span, cycle by cycle, contractor by contractor. Missing evidence surfaced before the circuit closes.

03

Risk-tiered queue built from your service territory

Transmission-adjacent spans, HFTD Tier 3 circuits, PSPS-eligible feeders, and high-consequence areas surface first. Your limited QC headcount goes to the spans a plaintiff expert or NERC auditor will actually pick.

04

An evidence library that answers NERC, CPUC, and litigation discovery

Span-level work traceable from the work order to the final sign-off. One-click exports formatted for FAC-003-5 evidence, CPUC WMP QDR reporting, and litigation production.

What a NERC FAC-003-4 audit finding reads like.

Three evidence gaps inside a single 12-span patrol. These are the kinds of redlines PacketUpload catches at cycle close, not six months later when the audit binder ships.

FAC-003-4 audit note · VM-72-9102
Transmission ROW · Cycle close 04.02.26
FINDING
01
MVCD clearance not photographed at measurement
Span 42-188 attested compliant. No calibrated measurement photo on file. Auditor cannot reproduce the Gallet distance from the submitted evidence.
NERC FAC-003-4 R3
02
Removed-tree GPS missing on two locations
12 trees logged, 10 with GPS. Two removals cite “Span 164, south side” as the only locator. ROW-audit exposure on the next cycle.
NERC FAC-003-4 R4
03
Before/after photo pair is non-comparable
Before-photo taken at 30° elevation. After-photo at 60°. Auditor cannot validate storm-hardening work against the pre-work condition.
NERC FAC-003-4 R3.2

From the contractor’s camera roll to your FAC-003-5 evidence file — verified.

PacketUpload sits between your contractor field crews and your regulators. Contractors submit evidence as they already do; you receive cited, cross-referenced compliance proof.

Today Trust and Pray

  1. Crews finish a cycle and upload zip files. Asplundh, Wright Tree Service, Davey Resource, and Lewis crews each submit in their own format — Clearion exports, OSI Monarch, native app dumps, photos texted to the forester.
  2. A forester spot-checks a sample. 2–5% of packets reviewed by hand. The other 95%+ get an automated completeness check and move on. Nobody actually measures MVCD from any of those photos.
  3. Annual FAC-003-5 audit or CPUC WMP review lands. Evidence for transmission spans, HFTD circuits, and high-consequence areas assembled from scratch. Weeks of scramble. Evidence gaps surface first at the auditor’s desk.

With PacketUpload Cited Evidence

  1. Contractor submissions parsed on arrival. Drone, LiDAR, satellite, ground photos, and arborist reports parsed as they land — from Clearion, OSI Monarch, DroneDeploy, AiDash, Overstory, or direct upload. Normalized to your UVM plan schema.
  2. MVCD and ANSI A300 checks, span by span. Measured clearance distance extracted. Species classified. Pruning cuts checked against ANSI A300. AAA Z133 safety observations flagged. Missing pre-work assessments surfaced before the cycle can close.
  3. Risk-tiered QC queue surfaces your real exposure. Transmission FAC-003-5 spans, HFTD Tier 3 circuits, WMP-committed work all prioritized. Your forester reviews the 5% that actually matter — with evidence already cited.

Runs with the UVM platforms, imagery providers, and contractor tools you already use.

GIS and UVM platforms plan the work. Imagery and sensor vendors capture the evidence. We verify that the work planned happened to specification — and that your contractor’s evidence holds up under FAC-003-5 audit and WMP review.

We run alongside the UVM, GIS, imagery, and contractor stacks utilities and line clearance firms already operate — Esri ArcGIS, Clearion, OSI Monarch, AiDash, Overstory, DroneDeploy, Trimble Forestry. Exports align with the NERC FAC-003-5 evidence formats, CPUC Wildfire Mitigation Plan QDR templates, and the litigation production standards plaintiff counsel have been testing since the 2017 fire season.

Grounded in the standards your reliability, wildfire, and litigation defense teams already cite

NERC FAC-003-5 evidence-readyNERC CMEP-alignedANSI A300 pruningAAA / ANSI Z133 safetyCPUC Wildfire Mitigation PlanCalifornia PRC 4293FERC Order 693IEEE 1366USFS / BLM Integrated Vegetation ManagementUtility Arborist Association

What FAC-003 compliance officers and WMP leads actually ask.

What kinds of vegetation packets does PacketUpload handle?

Pre-work assessments (foot patrol, drone, LiDAR), in-progress crew photos, post-work sign-offs, AAA Z133-compliant arborist reports, satellite imagery (Overstory, AiDash, Planet), drone orthomosaics, GPS-tagged MVCD clearance measurements, annual UVM plan compliance filings, and CPUC Wildfire Mitigation Plan Quarterly Data Reports.

How is this different from GIS-based UVM platforms like Clearion or OSI Monarch?

GIS and UVM platforms plan the work and track where crews are scheduled. PacketUpload verifies that the work actually happened to NERC FAC-003-5 and ANSI A300 specification — from the evidence your contractors submit. The two are complementary, and we integrate with both.

Does this help with FAC-003-5 audit preparation?

Yes. Every extraction cites the source document, timestamp, and geocoordinate. We generate FAC-003-5-formatted evidence exports per applicable transmission span and per cycle — and flag gaps (missing pre-work MVCD assessment, incomplete annual inspections, non-responsive spans) before the NERC Regional auditor does.

How does this support CPUC Wildfire Mitigation Plan evidence?

We populate the WMP QDR schedules (vegetation management, clearance, and risk assessments) from the same evidence base, tag HFTD Tier 2/3 circuits and PSPS-eligible feeders, and support the three-year WMP re-filing cycle with cited evidence rather than summary attestation. Works for PG&E, SCE, SDG&E, Liberty, and PacifiCorp WMP programs.

Can this be used by our line clearance contractor directly?

Yes. Asplundh, Wright Tree Service, Davey Resource Group, Lewis Tree Service, and regional firms run our QC layer on the contractor side to catch issues before the customer utility does — which shortens payment cycles and reduces re-work on packets. A mutual-benefit deployment pattern.

What about outside California? Does this work for Southeast / Midwest utilities?

Yes. FAC-003-5 is federal and applies across NERC regions. Outside of wildfire-focused states, the primary drivers are IEEE 1366 reliability (SAIDI / SAIFI), NERC transmission audit evidence, contractor QC for the Big-4 line clearance firms, and — increasingly — weather-driven risk (derecho, hurricane) overlay onto the same UVM program.

What does PacketUpload decide, and what stays with our forester?

PacketUpload extracts measurements, flags missing evidence, and assembles the FAC-003-5 and WMP evidence files. It does not certify compliance or sign the auditor’s attestation — your forester and regulatory counsel make the final call on every flag. Low-confidence extractions surface with reason codes, not pass/fail verdicts.

Make compliance evidence-based, not story-based.

Send us a sanitized cycle packet — we’ll come back with fit, the first checks we’d encode, and a pilot scope within two business days.

Tell us your transmission-span count, HFTD tier exposure, and line clearance contractor mix. Prioritizing FERC-regulated transmission owners, CPUC IOUs, and large utilities in wildfire-risk states.

Request a briefing

Or reach regulatory affairs at join@packetupload.com