The 100 kV Blind Spot Is Closing. Can You Prove the Work You’ve Already Done?

Ask a vegetation manager at a large transmission owner how many circuit miles they maintain and you will get a confident number. Ask how many of those miles they could produce dated, corroborated, auditor-ready evidence for by Friday, and the answer gets more careful.

That gap is about to matter far more than it does today.

What NERC actually filed

On 1 May 2026, NERC filed a report with FERC called Reducing the Risk of Wildfire Ignition by the Bulk Power System. It was not a voluntary exercise. It traces back to Executive Order 14308 of 12 June 2025, which directed FERC and three cabinet secretaries to consider rulemaking on practices that cut wildfire ignition risk from the bulk-power system without raising costs for end users. FERC convened a technical conference that October and ordered NERC to report back by the following May.

The headline regulatory recommendation is short enough to quote. NERC should pursue modifications to FAC-003 so the transmission vegetation management standard applies to facilities rated 100 kV and above, rather than 200 kV and above as it does today.

One sentence. Potentially tens of thousands of newly in-scope circuit miles across the industry.

The data behind it

This is not a hunch. Workshop participants kept returning to what they called the “100 kV blind spot,” and the numbers are hard to argue with.

In Western Interconnection wildfire data from 2017 to 2024, 43.5% of wildfire events on NERC-jurisdictional transmission lines occurred on 100 to 199 kV facilities. Another 35.8% were on 200 to 299 kV lines. The largest share sits in the voltage class the main vegetation standard does not cover.

Vegetation-contact outages tell a starker story. On 2025 data, roughly 86% of them happen on 100 to 199 kV lines.

Those circuits move power around a region rather than across the country. They run through tighter rights-of-way, closer to trees, often where a single contact has somewhere to go. For the entire life of FAC-003, they have sat outside it.

The part nobody is discussing

Most commentary since May has focused on cost. More miles, more crews, more budget. Fair enough. But that framing misses what actually produces audit findings.

Utilities are not ignoring their 100 to 199 kV lines. They patrol them, they cut them, they respond to them. In most organizations those circuits run under internal standards that resemble FAC-003 in substance. What they lack is the evidence architecture that regulated circuits built up over fifteen years: the dated inspection record tied to a specific span, the work order that closes against it, the contractor completion file that reconciles to both, and the lineage that lets an auditor trace a figure back to a system of record without taking anyone’s word for it.

That architecture did not appear by accident on 200 kV lines. It was built deliberately, because the standard demanded it. Not building the same thing where the standard was silent was a sensible use of finite resources. It simply happens to be the decision that comes due now.

What “in scope” costs you in practice

Here is the uncomfortable arithmetic. The work on those lines has been happening for years. The proof of it, in most cases, has not been kept to audit standard. When scope expands, you get no credit for history you cannot substantiate. You start from whatever you can evidence on day one.

Regulators have been consistent about this. Operations that perform the substantive compliance work but cannot produce audit-ready evidence still receive findings. The failure mode is rarely negligence. It is retrieval.

Retrieval is where the difficulty sits, because the data is not missing so much as scattered. Inspection findings live in one system, asset records in GIS, completion in a work management platform, contractor detail in files that may not be yours at all. Each source is accurate. Assembling them into one defensible chain, per span, per date, is the job that eats the month.

You have less time than two years suggests

Nothing is enforceable yet. This has to clear NERC’s standards development process and then FERC approval, which realistically puts enforceable obligations around 2028 or 2029. FERC has also mandated biennial reporting through October 2034, so the subject is not going away.

Two years sounds comfortable. For this problem it is not, because what you need is not a trimming program. It is an evidence trail, and evidence trails are retrospective. The record you will want in 2029 is being created, or not created, in 2027. A utility that starts capturing audit-grade evidence on sub-200 kV circuits next year walks into its first audit with two cycles of history. One that waits for approval walks in with intentions.

Four things worth doing now

None of these require a decision from NERC first.

Inventory honestly. Work out how many circuit miles sit between 100 and 200 kV, then be specific about what evidence exists for them today versus your 200 kV-plus assets. The gap is usually wider than people expect.

Extend the record, not the programme. You probably do not need to change how those lines are managed. You need the same inspection, work-order and completion records you already produce on regulated circuits, against the same asset identifiers.

Fix identity before volume. If a span carries one identifier in GIS and another in work management, no amount of extra data will reconcile it. Common identity is the prerequisite for everything else.

Test it with a real question. Pick a circuit, pick a date eighteen months back, and ask someone to produce the evidence pack. However long that takes is your baseline.

A closing thought

The utilities that handle this well will not be the ones that trim the most. They will be the ones that treated evidence as a product of the work rather than a report written about the work afterwards.

That is a data problem before it is a compliance problem. In practice it means one governed source that inspection, GIS, work orders and contractor records all feed into, so any figure in a filing traces back without a scavenger hunt.

If you are sizing up what the 100 kV expansion means for your evidence position, that is a conversation worth having while the standard is still being drafted.

Epikso works with electric utilities on compliance reporting across wildfire mitigation, vegetation management and asset management, turning existing GIS and field data into audit-ready evidence. We run a short working session that traces your top compliance reports back to the systems feeding them.

Sources

• NERC, Reducing the Risk of Wildfire Ignition by the Bulk Power System, filed with FERC 1 May 2026
• NERC, report filing to FERC
• American Public Power Association, FERC Announces Technical Conference on Wildfire Mitigation and the Bulk-Power System
• TCI Magazine, Executive Order Aims to Improve and Modernize Wildfire Prevention and Response
• LiveEO, NERC Wildfire Report: What Utilities Need to Know
• Integ Consulting, NERC Compliance Evidence Management Best Practices