Demystifying Operations and Maintenance Plans for Transmission

Why Operations and Maintenance Plans Matter Now

Operations and maintenance (O&M) plans have become essential tools for utilities managing transmission infrastructure across federal lands. While these plans help satisfy regulatory requirements, their greatest value may be in improving wildfire risk management, streamlining agency coordination, and creating predictable pathways for maintaining critical energy infrastructure.

While utilities have maintained transmission systems for decades, increasing wildfire risk and a shifting regulatory context have changed how O&M activities are documented and reviewed.

Across the western United States, wildfires are growing larger and more destructive, and power-line ignitions have contributed to several high‑profile events. This has highlighted the role that routine operations—especially vegetation management—can play in mitigating that risk. In this context, O&M plans are more than compliance documents; they’re a way of keeping our communities safe and protecting our environment.

This shift in understanding the function of O&M plans is changing how utilities develop them and how agencies review them.

The Regulatory Framework for Operations and Maintenance Plans and their Benefits

A 2018 amendment to the Federal Land Policy and Management Act (FLPMA), which added Section 512, directed federal land management agencies to establish requirements governing the review and approval of electric power operations, maintenance, fire prevention, and facility management plans and agreements for rights-of-way (ROW) on federal lands. Subsequent rules and guidance from the U.S. Forest Service (USFS) and Bureau of Land Management (BLM) clarified expectations around grid reliability, wildfire prevention, and vegetation management.

The practical effect of this framework has been a move away from piecemeal maintenance authorizations toward programmatic O&M plans that define activity classes and outline approval and notification processes. For both utilities and agencies, this creates an opportunity to reduce administrative friction.

Well-assembled O&M plans can streamline project review, reduce repeated consultation, and save time for agencies and utilities. They help create predictable pathways for routine and non-routine maintenance and can reduce uncertainty when emergency responses are needed. At SWCA, we’ve already seen how the relationships cultivated through O&M planning have improved coordination and accelerated wildfire responses.

However, these benefits depend on how the planning process is managed.

Transmission line in the field

Team Alignment is Key

Utilities and agencies are both navigating changing expectations. For utilities, multiagency coordination can be daunting. At the same time, agencies may struggle with capacity or inconsistent institutional knowledge. Successful planning teams should recognize these realities and account for them with intentional engagement.

• Engage Decision Makers Early. Although the regulatory framework has been spelled out in law and agency policy, agency employees will need time to hash out its full implications. In the meantime, it will be important to get project teams aligned around the purpose, scope, and goals of O&M plans. Securing buy‑in from regional agency leadership and key resource specialists will help prevent reopening fundamental questions late in the process. And developing shared goals at the outset can provide a touchstone the team can revisit to maintain focus. Clarifying early what constitutes binding requirements versus discretionary guidance can prevent misunderstandings later.
• Leverage the Existing Administrative Record. The wider administrative record can also provide support. Leveraging existing land use plans, biological opinions, best management practices, and prior approvals can demonstrate consistency and keep review within the scope of Section 512 of the FLPMA. For example, SWCA worked with utility and agency partners to fold an O&M plan into the scope and analysis of an existing USFS maintenance “No Effect” determination under the auspices of the Endangered Species Act. This required careful coordination to make sure the activities allowed under that determination enabled both partners the latitude to accomplish their respective goals. That was not a foregone conclusion, but the coordination saved the USFS and U.S. Fish and Wildlife Service valuable time, reducing consultation workloads and accelerating approval of the utility’s O&M plan.
• Develop a Shared Understanding of Operational Realities. Field visits, documentary evidence (aerial imagery, GIS data, etc.), and input from key utility operations staff can contribute to a shared understanding of site conditions, the extent of plan coverage and realistic impact of the O&M plan. Similarly, utilities should take steps to understand how maintenance actions are reviewed and implemented by their agency partners. This can enhance their understanding of the agency’s preferences, constraints, and overall structure, cultivating more realistic expectations around the agency’s role.

In Practice: Site Visits Keep Operations and Maintenance Plans Grounded

SWCA recently partnered with Pacific Power and the USFS to develop a transmission line O&M plan that covered portions of the Six Rivers National Forest. A combination of GIS-informed habitat modeling and site visits played a key role in developing a common understanding of plan activities and potential biological impacts.

With approval from the utility’s strategy team, SWCA’s biologists and GIS specialists worked with USFS biologists to develop habitat models for three federally listed species for the 25-mile-long utility corridor. To develop the habitat models, the team integrated knowledge of the local landscape using LiDAR tree height and canopy cover spatial signatures with well-researched, habitat-based functional relationships to identify areas most likely to support listed species’ breeding activity. Together, SWCA and USFS biologists performed site visits that helped ground-truth those models over a few days. This allowed us to quickly identify a small subset of areas along the transmission route that would require enhanced avoidance measures for listed species protections (e.g., noise disturbance restrictions based on distance from breeding habitat). The geographic scope and avoidance measures were then shared with the utility operation team, who confirmed that they could integrate those measures into their annual workflow for activities like vegetation management.

This reduced the need for additional surveys or consultation with USFWS and reduced the workload for the agency and utility.

Site visits not only help keep the team’s approach grounded in existing conditions but also clarify the actual scope of proposed activities. In addition to the habitat mapping exercise, SWCA facilitated visits to observe typical O&M activities in action. This allowed agency specialists to measure noise levels on-site at set distances from the work location. Observing sound dissipation directly helped the project team develop pragmatic measures to avoid noise disturbance to nesting and denning wildlife without hindering normal operations.

Taking the time to make sure that all parties shared a robust understanding of on-the-ground conditions and the practical implications of proposed actions helped identify and resolve critical issues more quickly than a purely desktop-based approach. The effort also fostered a more concrete understanding of what O&M activities entail and provided a common baseline for everyone to reference when evaluating them.

Transmission line in the field.

Anticipating Common Problems

Even with strong engagement some challenges are unavoidable:

• Federal staff turnover can disrupt the continuity of the planning team, requiring repeated onboarding and verification of prior agreements. Fortunately, this is easy to anticipate and address. We’ve learned to “over-document” even trivial or incremental decisions, because that creates a record that new team members can use to understand how the project evolved. New team members are not necessarily bound by previous decisions, but they’re more likely to respect them if we help them understand how and when they were made.
• Requirements from other project types are sometimes misapplied to routine ROW maintenance. Although O&M Plans are not “new,” developing them at the current scale and complexity is, so it’s not surprising that agency representatives might reach for a more familiar rule or project precedent for guidance that may not be applicable to O&M activities. Managing the process must involve being ready to help guide team members back to more relevant considerations.

Better Plans, Reduced Risk, Safer Communities

O&M planning is more than an administrative exercise. For transmission projects that intersect with federal lands, they function as risk management tools, wildfire mitigation strategies, and mechanisms for long-term agency coordination. Their success depends on early alignment, consistent engagement, and repeated reinforcement of intent. Utilities that treat O&M plans as strategic tools rather than compliance documents will be better positioned to protect infrastructure, natural resources, and the communities that depend on them.

SWCA Can Help

If you have any questions about building effective O&M Plans, please contact one of our experts.