The Tree Care Industry Association (TCIA) recently submitted comments in response to the Federal Energy Regulatory Commission’s (FERC) request for input on cost-effective wildfire-mitigation practices. FERC’s request is part of the Commission’s implementation obligations under Executive Order (EO) 14308.

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Executive Order 14308
On June 12, 2025, President Trump signed Executive Order 14308, “Empowering Commonsense Wildfire Prevention and Response,” to streamline federal wildland fire governance, encourage local wildfire preparedness and response and strengthen wildfire mitigation. The EO follows the January 2025 Los Angeles wildfires, which the Trump administration cites as evidence of delayed and inadequate wildfire response by state and local governments, underscoring the need for faster, more coordinated and more effective prevention and wildfire-
mitigation efforts.

The order specifically addresses the risk of wildfires associated with electric-utility infrastructure, instructing, in Section 4(d), FERC and the Departments of the Interior, Agriculture and Energy to consider initiating rulemaking proceedings to establish best practices for reducing wildfire-
ignition risk from the bulk-power system without increasing costs for electric-power consumers.

FERC looks at reducing risk
In response to EO 14308, FERC held a Wildfire Risk Mitigation Technical Conference on October 21, 2025, to discuss cost-effective ways to reduce
wildfire-ignition risks from the bulk-power system. In addition to the conference, the Commission directed the North American Electric Reliability Corporation (NERC) to assess the need for new or revised reliability standards and to prepare a report identifying best practices for wildfire mitigation.

The conference featured panels on grid-focused best practices for wildfires and on leveraging technology to monitor, evaluate and mitigate wildfire risks. The first panel examined interagency collaboration through data sharing, vegetation management and the need for environment-specific mitigation strategies. Experts highlighted the importance of reliable field data, the use of predictive modeling and constant improvement of wildfire-mitigation plans. The second panel featured conversations on LiDAR, AI and dynamic line-rating systems, exploring how the development of advanced technology can monitor and mitigate wildfire risks.

Under the Order Directing Report (Docket No. RD25-9-000), NERC is required to submit its findings by May 1, 2026. The report will identify best practices for wildfire mitigation, including vegetation-management techniques, safer operational and engineering approaches and the use of emerging technologies that could mitigate wildfire risk. It also will evaluate how these best practices align with existing reliability standards and identify any gaps where new or revised standards may be necessary.

In conjunction with the NERC report, FERC invited stakeholder comments on the technical conference, stating that these two actions will build the record needed to determine whether additional reliability standards or formal rulemaking are warranted.

TCIA’s advocacy of wildfire-risk mitigation
In October 2025, TCIA submitted comments to FERC’s Second Supplemental Notice of Wildfire Risk Mitigation Technical Conference and the related Order Directing Report to NERC, recommending that the Commission establish a minimum federal standard of care for utility-vegetation-management (UVM) contractors conducting pre-inspections of hazard trees based on the ANSI A300 Standard.

Though current standards prescribe clearance distances, they do not establish how to identify or evaluate hazardous trees in the field, leading to inconsistent practices, elevated legal risks for UVM contractors and difficulty securing insurance. Establishing a federal baseline standard, based on the Level 1 Limited Visual Assessment of the ANSI A300 Tree Care Standard, would create clear expectations for how hazard trees are to be identified under approved vegetation-management programs, promote more consistent application of risk-assessment techniques across regions and provide insurers with a well-defined, consensus-based framework for evaluating contractor practices.

Further, as highlighted in TCIA’s comments, the ANSI A300 standard is already commonly used by UVM contractors, is recognized by the Utility Tree Risk Assessment Best Management Practices (UTRA BMP) and is referenced by NERC itself, in various utilities’ Wildfire Mitigation Plans cited in NERC’s 2025 “Wildfire Mitigation Guide.”

Consistent application of a defensible, repeatable process for hazard-tree identification not only improves risk outcomes but also strengthens the legal defensibility of utility and contractor decisions. By incorporating established, consensus-based arboricultural standards such as ANSI A300, and by improving coordination across agencies and responsible entities, the Commission and NERC can help ensure that vegetation-management programs are both reliable and cost effective.

Basil Thomson is a partner at Ulman Public Policy, TCIA’s Washington, D.C.-based advocacy and lobbying partner.