Text

Site Audit References from Nine Mile Point Nuclear Station, Units 1 and 2 - Transmission RIGHT-OF-WAY Management Program
	ML043130295
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Site:	Nine Mile Point
Issue date:	11/01/2003
From:	; National Grid Transmission USA
To:	Leslie Fields; Division of Regulatory Improvement Programs
	Fields L, NRR/DRIP/RLEP, 415-1186
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Item 9 Transmission Right-of-Way Management Program

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Table of Contents F O R E W O R D..................................................................................................................... iv I. DESCRIPTION OF ORGANIZATIONAL STRUCTURE .

A. Territorial Description .

B. Management Description .

C. Territorial Regions. 3 D. Names/Terminology .3 II. DESCRIPTON OF THE TRANSMISSION SYSTEM . . 5 A. The Electric Transmission System .5 B. The Gas Transmission System .6 IIl. DEVELOPMENT OF THE TRANSMISSION RIGHT-OF-WAY MANAGEMENT PROGRAM. 9 IV. CYCLES AND TRENDS . 19 V. ECOLOGICALLY-CENTERED VEGETATION MANAGEMENT .23 VI. TRANSMISSION RIGHT-OF-WAY MANAGEMENT PROGRAM: GOALS, OBJECTIVES, AND STRATEGIES .34 VII TRANSMISSION RIGHT-OF-WAY PROCEDURES ....................................... ;.49 A. Identification of ROWs Recommended for Treatment .49 B. Procedure for Scheduling and Reporting Corrective Action .51 C. Determination to Schedule or Delay Maintenance .52 D. Procedure for Budgeting and Scheduling of Routine Maintenance . 54 E. Transmission Right-of-way Inventory .56 F. Implementing the Modified "Wire Zone/Border Zone" Concept . 63 G. Definitions and Selection Criteria of Vegetation Management Techniques.........................................................68

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I~IL-H. Field Completion and Reporting ............................... 101 I. Landowner Notification ............................... 101 J. Customer Inquiry and Complaint Resolution ............................... 102 K. Program Implementation ............................... 102 L. Measure of Program Effectiveness ............................... 106 M. Regulations, Permits and Approvals ............................... 107 N. Testing of New Material and Mixtures ............................... 110

0. Research ........... ;.1.11 P. Program Review ............ 11.

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APPENDICES Appendix 1: Article VII Specials for Electric Transmission Facilities Appendix 2: Article VII Specials for Gas Transmission Lines Appendix 3: Environmental Energy Alliance of New York Position Paper Appendix 4:: Summary of National Grid's Research Appendix 5: Environmental Protection Agency's Pesticide Environmental Stewardship Program -

Appendix 6: Transmission Masters for Fourth Cycle Appendix 7: Gas Masters for Fourth Cycle Appendix 8: Inventory Appendix 9: Vegetation Management Notification Materials Appendix 10: Niagara Mohawk's Annual Reports to the Public Service Commission Appendix 11: Environmental Guidance "EG-502, Unauthorized Dumping", "EG-504, Pesticide and Herbicide Application" and "EG-202 Herbicide Spill Reporting" Appendix 12: Special Plan Conditions Which Apply Within the Adirondack Park-iii

U Foreword:

On December 20, 1977, Niagara Mohawk was ordered by the New York State Public Service Commission (PSC) to present specific plans for an ecologically sound, long-range, system wide, right-of-way vegetation management plan (Case 27277). In May 1978, Niagara Mohawk submitted its program to the PSC and approval was granted in an Order issued October 25, 1978.

On December 15, 1980, Section 84.2 of 16 NYCRR Part 84 was adopted in PSC Opinion 80-40, Case 27605, requiring all investor-owned utilities to develop and submit for PSC approval, a long-range Transmission ROW Management Program by April 1981.

A revision of the approved May 1978 Transmission Right-of-Way (ROW) Management Program was submitted to the PSC in May 1981, in response to the new Part 84 Regulations. Niagara Mohawk was granted an extension from the original April 1981 filing deadline to May 1981. Subsequent revisions were made in February 1982, October 1984, March 1986, and October 1989. The revised and PSC approved March 1986 Plan included revisions to establish special considerations for the Adirondack Park.

On May 5, 1995, the PSC issued proposed revisions to Part 84 Regulations, assigning Case No. 94-M-0101. Subsequent discussions with stakeholders, and exchange of comments over the next six years have resulted in agreement by the investor-owned utilities to update all existing plans under the current rules. This revision is provided in response to those discussions, and incorporates the issues and concerns raised during the six years of talks.

As has been consistently demonstrated during those discussions, and is reaffirmed by this document, the original Niagara Mohawk order (Case 27277) together with the Part 84 rulemaking (Case 27605), have been very successful in accomplishing their goals and objectives. The New York utilities have become nationally recognized industry leaders in the adoption and application of ecologically sound vegetation management practices, combined with the use of research to guide vegetation management philosophies and practices. The results have been significant reductions in herbicide use, improved reliability and safety, and effective cost management.

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CHAPTER 1 Description of Organizational Structure A. Territorial Description A merger between the former Niagara Mohawk Power Corporation and National Grid USA was completed in January 2002, forming one of the largest, investor-owned utilities in the United States. The former Niagara Mohawk portion will continue to serve more than 1.5 million electric customers across 24,000 square miles of upstate New York, including residential, commercial, and industrial service to 31 cities and 639 towns. Gas service is provided to 550,000 customers in 197 cities, towns, and villages across 15 counties in central, northern, and eastern New York.

B. Management Description The Board of Directors of National Grid are elected by the stockholders. National Grid USA will be organized into a Transmission Group for the combined companies, with a Distribution Group in New York, a Distribution Group in New England, and a Technical Services Group as shown in the following organization chart.

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X The chart below illustrates the organizational structure for the Transmission Group.

Within this group, Vegetation Management reports under the Vice President of Transmission Network Planning and Operations.

Transmission Regulatory Account Asset and New York Control Financial Relations Managers Maintenance Policy, Center Reporting Planning, &

ISO Energy Replacement New England Rates &

Representation Measurements Transmisslon Line Control Center Forecasting

& Billing Services Line Engineering, OPratlonal Standards & Project Plannng &

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A National Grid The Manager of Transmission Forestry is functionally responsible for administering and implementing right-of-way vegetation management policies, goals, and procedures throughout the company in accordance with this Program. The Manager of Transmission Forestry coordinates and monitors the implementation of the Transmission Right-of-way Management Program across New York.

Contact information for Forestry:

Thomas E. Sullivan Manager, Transmission Forestry National Grid 25 Research Drive Westboro, MA 01582 Telephone: 508 389-9086 E-Mail: Thomas.Sullivaneus.ngrid.com 2

Three Foresters, one each for the East, West, and Central Divisions, will report to the Manager of Transmission Forestry. They oversee the day-to-day implementation of this Program.

Program support is also provided by the Environmental Affairs group within the Technical Services organization for environmental permitting matters such as wetlands permitting, endangered species liaison, etc.

C. Territorial Regions The map on page 4 identifies National Grid's service territory. The Eastern Division includes the Capital and Northeast Regions and provides service to electric and gas customers. The Central Division includes the Mohawk, Central, and Northern Regions and also includes electric and gas service. The Western Division includes the Frontier and Western Regions (the Western Region was formerly two separate regions known as the Genesee and Southwest Regions) and provides electric service only.

D. Names/Terminolo2g The name National Grid is used throughout this document to reference the owner and operator of the New York electric and gas transmission systems that are included within this Program. When the term National Grid is used in a historic perspective, it is intended to describe the operations of Niagara Mohawk Power Corporation and it's predecessor companies. When the name National Grid is used in the present or future perspective, it is intended to describe the policies and procedures of the National Grid Transmission group and those personnel working to implement the Program.

3

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CHAPTER 2 Description of the Transmission Svstem The electric and gas transmission systems are organized within operating Regions and Divisions, with record keeping and reporting at the Regional level, and vegetation.

management coordination and supervision at the Divisional level. In 1984, the former Genesee and Southwest Regions were combined into one region now known as the Western Region. However, for record keeping and reporting purposes the Transmission Right-of-way (TROW) computer program continues to organize and track them as separate reporting areas using their original names of the Genesee and Southwest Regions.

A. The Electric Transmission Svstem The electric transmission system includes all bulk transmission (230 and 345 kV),

transmission (69 and 115 kV), and sub-transmission (23, 34.5, and 46 kV). The sub-transmission right-of-way and voltage classes are incorporated into this Program to provide uniform implementation of vegetation management policies, procedures, and practices. The Program incorporates all electric transmission that has been constructed since the mid-1970's under the environmental siting and construction requirements'of Article VII or Part 102 (Phase III) of the Public Service Commission law, regulation, or order. It is understood that approval of this Program acknowledges the incorporation of .

proven vegetation management practices in order to facilitate uniform and consistent management of the entire transmission'system. A listing of specific Article VII electric transmission facilities that are incorporated into this Program is provided in Appendix 1.

Appendix 1 also identifies and incorporates the special environmental and vegetation management concerns for each line addressed in the Article' VII process, and provides a brief comment discussing how these concerns are addressed or incorporated into the current Program.

The following table identifies the total miles of overhead electric transmission by voltage class, and by division as of 2001. There are 9,333 miles of electric transmission across the system, with 868 miles of underground and 8,465 miles of overhead construction.

Circuit Miles of Overhead Electric Transmission' by Voltage (kV) 345 kV 230 kV 115 kV 69 kV 46 kV 34.5 kV 23 kV Total East 343 187 - 1096 - 131 605 116 2478 Central 270 109 1547 17 367 626 353 3289 West 37 202 1266 146 977 70 2698 Total 650 498 3909 294 367 2208 539 8465 The transmission system includes 73,087 total acres of right-of-way. Of this there are 14,322 acres in open field, grasslands, lawns; 7,418 acres with trees or shrubs that did not 5

require maintenance in the past eight years; and 51,347 brush acres requiring some fonn of vegetation management.

The following chart is based on December 2001 data and identifies the right-of-way acres by Region and Division that are managed under this long range Transmission Right-of-way Program for electric transmission lines. "Open Field" includes any site that contains only grass or herbaceous species, including active cropland, pastures with no woody brush, lawns, commercial sites, and similar areas. "Brush - No Work" describes sites that contain woody shrubs or trees, but due to growth and clearance conditions, they do not require maintenance during this cycle. Finally, "Brush - Requires Work" describes those acres that require management intervention to control undesirable, tall growing woody vegetation.

Right-of-way Acres for Electric Transmission Open Brush Brush Field No Work Requires Work Total Capital 1,828 873 8,542 11,243 Northeast 2,790 1,023 7,125 10,938 East 4,618 1,896 15,667 22,181 Mohawk 1,352 1,014 5,165 7,531 Central 2,022 1,625 9,230 12,877 Northern 1,709 1,038 8,155 10,902 Central 5,083 3,677 22,550 31,310 Frontier 1,087 487 3,427 5,001 Genesee 1,591 616 3,584 5,791 Southwest 1,944 743 6,117 8,804 West 4,622 1,846 13,128 19,596 System 14,323 7,419 51,345 73,087 B. The Gas Transmission Svstem The gas system includes approximately 264 miles of pipeline and 1,468 acres that require maintenance, as identified in the following table. This data was first compiled for the 1993 draft filing for gas and remains current in 2001.

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Right-of-way Miles and Acres for Gas Transmission Pipeline Estimated Miles Acres Capital 99 240 Northeast 95 218 East 194 458 Mohawk 46 105 Central 243 591 Northern 98 233 Central 387 929 System 581 1387 Included within these totals are fourteen (14) gas transmission lines greater than 1,000 feet in length that have been certified by the PSC pursuant to Article VII of the Public Service Law. These lines cumulatively total approximately 10 miles in length and are listed in Appendix 2. Appendix 2 also identifies and incorporates the special environmental and vegetation management concerns for each line addressed in the Article VII process, and provides a brief comment discussing how these concerns are addressed or incorporated into the current Program.

During settlement hearings for Pipelines 56 and 58, National Grid agreed to the development of a generic plan for the long-term management of gas rights-of-way.

Similar requirements were also agreed to during settlement negotiations for Pipelines 63 and 64. A draft was developed and submitted to PSC staff in September 1993, and comments returned from the Staff in January 1994. Subsequent review and discussion of the right-of-way management requirements for gas transmission rights-of-way were addressed within the informal rulemaking process for proposed revision of Part 84 regulations.

Since National Grid's gas rights-of-ways are maintained on a regular mowing cycle to keep the right-of-way in mainly a grass and herbaceous condition, it was acknowledged that at most, herbicides were only occasionally required to restore control of undesirable woody regrowth that frequent mowing could not control. It was further acknowledged that the industry standard for maintaining gas rights-of-way was annual mowing.

(Mowing on National Grid's gas rights-of-way would generally be accomplished in accordance with the Transmission ROW Procedures section G.8.g. of this document, which discusses mowing in more detail.) Since the existing National Grid program effectively managed these pipelines on a longer cycle than was the industry norm, and since herbicides would only be used occasionally, it would not be necessary to develop a full generic plan for gas. Instead, when it became necessary to use herbicides within a gas right-of-way, National Grid agreed to follow the permitting requirements and selection criteria for choosing treatment methods and maintaining buffers that are 7

addressed by the electric program. It was further agreed that field inventories would not be required for gas rights-of-way.

In order to insure uniformity and consistency in vegetation management policies and practices, the Manager of Transmission Forestry, and the Foresters in each Division served as administrative consultants to the Gas Department for the completion of all vegetation management, and the implementation of all environmental restoration and compliance issues. In this capacity, the Manager of Transmission Forestry helps the Gas Department develop maintenance schedules, prepare budgets, supervise vegetation management contractors, and administer and implement vegetation management policies, procedures, and practices in accordance with the appropriate goals, objectives, and strategies of this Program.

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CHAPTER 3 Development of the Transmission Ripht-of-wav Management Program Historic Perspective:

Vegetation management on electric transmission rights-of~way (ROWs) in New York State can be divided into three eras. It began with the Manual Era of the early 1900's, continued through the Broadcast Era of the 1950's to mid-1970's, and evolved into the Selective Management Era that has been adopted by most ROW management programs used today.

The Manual Era:

The 1882 construction of Thomas Edison's Pearl Street Station in New York City marked the beginning of the investor-owned electric utility industry. This plant was a direct current facility capable of transmitting electricity just two miles.

The first alternating current generating station in America began producing powerin Buffalo in 1886. However, this plant did little more than supply electricity to light a few hundred incandescent lamps.

In "Niagara Mohawk, An Uncommon History," editor, R. F. Dischner writes "the 1890's saw one of the greatest standards controversies ever, The War of the Currents, as Nikola Tesla and Edison debated over the relative merits of alternating current (AC) and direct current (DC). Alternating current was more flexible and had the advantage of being able to be transmitted in large blocks over long distances. Direct current was supported by Edison, but required large amounts of copper and generating stations every two miles."

Mr. Dischner also writes that "when the Cataract Construction Company, under the leadership of Edward Dean Adams, was formed for the purpose of harnessing the power of (Niagara) Falls in 1886, there was no consensus on how that power would be transmitted. It took five years of study before electricity was selected over pneumatic and mechanical means." - ,.

Dischner continues to write, ','The construction of the immense tunnel that would carry water for more than a mile under the town of Niagara Falls was the largest engineering project of its day, and a risk of enormous proportions. The reward was the:

revolutionizing of modern life. A decision had to be made: whether to use direct current (DC) or alternating current (AC). Direct current, championed by Thomas Edison, seemed to have important advantages. However, alternating current was easier and cheaper to transmit over long distances, an important consideration for remote generating plants."

And finally, "alternating current won the day, and George Westinghouse won the contract to build the generators, basing his design on several theories and patents of Nikola Tesla," Dischner adds.

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When the switches were thrown at the Adams plant on November 15, 1896, it was the first large-scale effort to generate and transmit bulk power from a remote generating site over 22 miles of transmission line to the factories, plants, and streetcars of Buffalo.

In his book "Niagara Power, History of the Niagara Falls Power Company, 1886-1918" Edward Dean Adams includes a statement from Paul M. Lincoln describing this early attempt at AC transmission. Mr. Lincoln was the Operating Superintendent and Resident Engineer for the Niagara Falls Power Company with responsibility for supervising the operation of the new transmission line from 1896 to 1902. In his report, Lincoln describes the line as an 11,000-volt, three-phase line. While there were other plants transmitting power at even higher voltages, this line was both unique and of historical importance because of the amount of power it transmitted, the importance of the service it provided, and the distances over which this occurred. This line transcended anything that had been previously attempted. It was the goal of these earliest developers to replace the hydraulic, steam, and mechanical sources of power for the industrial engines of the day with dependable electric power for their motors. Continuity of service and reliability were essential from the beginning.

As early electrical engineers tackled the problems of porcelain insulators, switches, and protective devices, they soon learned the importance of sound tree trimming programs as well.

In an 1897 paper presented to the National Electric Light Association in Niagara Falls, J.G. White of the White-Crosby Company, the company who engineered and constructed the line, describes its first year of operation. In particular, Mr. White describes "one short interruption last winter was due to the dead limb of a tree blowing across the wires, illustrating thefact that all trees should be cut down for some considerable distance on both sides of any high voltage line."

In 1900, a new wood pole line was constructed to upgrade the system to 22,000 volts, and in 1906, a right-of-way was being purchased to construct a transmission line from Niagara Falls to Syracuse. The line used Sears, Roebuck and Co. Aeromotor windmill towers. The transmission grid continued to grow as this line was connected to others from hydroelectric plants on rivers in the Tug Hill plateau, the Adirondack Mountains, and across upstate New York. The importance of electricity and the electric transmission system in connecting our daily lives at work and at home is taken for granted today.

However, the importance of sound vegetation management can never be taken for granted.

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Just as today, these first transmission corridors required tree clearing at the time of construction and periodic maintenance to keep vegetation from growing back into the lines. As -

illustrated by this early photo, the lack of mechanization made the initial clearing / -

and subsequent maintenance very 'l laborious. The first vegetation management tools included crosscut ' i . .

saws, small handsaws,'and brush hooks.

Horses, early tractors, and bulldozers.

were used to move logs and larger wood, me>+9-46 >

while laborers piled the smaller limbs.

- Photo compliments of Jim Orr, Asplundh Tree Co., Inc.

Shown here is a worker using a brush hook.

Chain saws began to be developed for logging applications in the 1930's and 1940's,'but these were large two-man machines. While they may have been useful for clearing new lines, they were far too cumbersome for maintenance work.

Periodic reclearing was usually done by line crews during the off-season (winter) when line construction itself was difficult. This reclearing involved considerable time and money, and the results were unsatisfactory in terms of long-term vegetation control.

Essentially, the Manual Era could be described as managing clearances rather than managing vegetation for several reasons.

The root system of a plant is one of its primary food storage sites. After cutting, trees and woody shrubs rejuvenate themselves from dormant or adventitious buds, producing fast-growing stump sprouts and/or root suckers. Growth rates for these sprouts and suckers can be many times faster and taller than seen in normal seedling development. 'This happens because the tree's severed root system continues to 'supply food and nutrients to the new growth more abundantly than it would in a seedling, enabling the existing root system to quickly reestablish a root-to-crown balance.

When mechanical clearing occurs during the growing season, new growth often resumes within'a few days. However, when clearing is done in the dormant season, root reserves are at their highest, and the tree simply waits until the next spring before sending out new growth. In trying to survive and restore -balance, it will send out a multitude of new stump sprouts and root suckers. ;Growth rates of 12-15 feet in a single year have been reported, and tree densities can easily range from 10,000 to 20,000 stems per acre with repeated manual clearings.

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Photos compliments of Jim Orr, Asplundh Tree Co., Inc.

The photos above illustrate the development of both stump sprouts and root suckers from a single Aspen stem in a field setting. Numerous stems are developing from both the stump and the root system, and the extensive spread of the root system is becoming evident in the photo on the right.

The Broadcast Era:

The commercial application of herbicides was introduced in the United States in the late 1940's, using the chemical Ammate. It was the first alternative to costly hand clearing methods, and it also improved worker safety. National Grid's first herbicide treatments made with Ammate were in 1951. However, Animate was a contact herbicide that only provided "top kill" of woody brush, with limited translocation, or movement into the roots. As a result, stump sprouts and root suckers continued to create quick regrowth.

Another problem with Animate was its highly corrosive effect on spray equipment.

Eventually, smaller one-man chain saws found their way into the market and began to be introduced into right-of-way maintenance activities, replacing axes and brush hooks to reclear lines. This, combined with the fact that Animate was showing some effectiveness as a stump treatment when mixed with a small quantity of water and applied as a paste, began to expand the "tool box" for the early right-of-way manager.

But, with woody brush densities averaging 10,000 to 20,000 stems per acre, early managers even considered shrub communities problematic. As a result, all woody tree and shrub species were treated in an effort to establish clear, easily accessible rights-of-way.

The introduction of the phenoxy herbicides (2,4-D and 2,4,5-T) in the 1950's provided the first products to effectively translocate from the treatment area to the growth sites of the plant's stem and roots, and provide effective root "kill." The first formulations were amine salts that were soluble in water.

The subsequent development of low volatility esters expanded 2,4,5-T treatment options, providing the first basal applications. Basal treatments used fuel oil as the carrier for the herbicide instead of water. They targeted the lower stem and all exposed roots of the 12

plant. -The oil base enabled the pr'oduct' to penetrate the waxy bark substances, but once inside the bark, the herbicide solution did not mix well with the water-based transport system of the tree. Movement up or down the stem was poor, and these treatments could not control root sprouting.

National Grid set its first test plots with 2,4,5-T as a foliar application in the summer of 1953. By 1956, high-volume ground broadcast treatments had become so effective that 2,4-D and 2,4,5-T were fully incorporated into brush treatment efforts. In the next few years, these products would become important tools for field supervisors facing thousands of miles of tall, dense brush. High-volume broadcast applications promised to be an economic way to reduce this problem.

The first spray equipment for right-of-way use was adopted from crop and orchard spray operations, as illustrated in the above photo.

Photo compliments of Jim Orr, Asplundh Tree Co., Inc.

The use of herbicides soon began to reveal its own set of control problems. Each product exhibited varying degrees of effectiveness among species, controlling some, but not others, especially ash. Applicators learned that tank mixes of two or more products were necessary for effective, broad-spectrum control. Tank mixes continue today, enabling right-of-way managers to tailor products, mixes, and treatments to meet a variety of environmental and public issues, as well as plant conditions found along the right-of-way.

Picloram was introduced in the 1960's and proved very effective when tank mixed at higher rates with 2,4,5-T in controlling a broad range of hardwood and coniferous species. .

The 1960's saw the introduction of helicopters for aerial spraying of rights-of-way for brush control and also development of the micro-foil boom that greatly improved drift control from aerial spraying. As a result, it became the treatment of choice on many lines. Helicopter treatments applied six gallons of herbicide concentrate per acre, while high-volume ground broadcast required three-to-nine gallons per acre, depending on 13

brush densities. Helicopter applications and high-volume ground broadcast with tank mixes or 2,4,5-T and Tordon were the mainstays of National Grid's program until 1979 when the Environmental Protection Agency (EPA) banned the use of 2,4,5-T in the United States.

The Birth of Selective Management:

Research into herbicide use on rights-of-way began almost as early as the first treatments.

The work of Drs. Egler and Neiring in New England began to explore both old field succession and the stability of shrub communities in the 1940's and 1950's. By the 1970's, Egler's theories about the stability of shrub communities became popular with New York regulators.

In 1951, the Penn Electric Co. teamed with manufactures, contractors, the Pennsylvania Game Commission, and Drs. Brambles and Byrnes of Purdue University to conduct one of the first studies on the impacts of right-of-way spraying on wildlife habitat. Their first work was published in 1953. Today, this study spans nearly 50 years and is commonly known as the "Bramble and Byrnes" or "Gamelands 33" research. It has become a cornerstone of vegetation management theory and practice.

The work of these early pioneers began to set the stage for the inclusion of science into the art of right-of-way management. In the 1960's utilities also began to hire forestry professionals for vegetation management. When combined with the environmental movement of the 1970's, the public and the regulators, the utilities themselves prepared for adoption of selective management principles and a more ecologically-centered vegetation management approach.

Selective vegetation management began in 1970 when New York State enacted Article VII of the Public Service Commission (PSC) law, strengthening environmental requirements and public participation in the siting and construction of "new" transmission lines. Herbicide use was highly scrutinized, and selective clearing and treatment methods were adopted for these lines. Specifications were designed "to preserve low growing shrub communities and small tree species to the extent practicable." The PSC's role and involvement in routine maintenance on "existing" lines was still limited.

In the early 1970's right-of-way maintenance remained mostly reactive and treatment deferral was a common practice. The budget and scheduling process was still decentralized, with local T&D supervisors determining priorities. The concepts of cyclic scheduling and budgeting were not fully supported at either the district or system levels, and annual budget support was inconsistent.

The energy crisis of 1973, combined with Con-Ed's failure to declare a common stock dividend in 1974, sent shockwaves through the utility industry. Vegetation management programs were severely cut throughout New York, and at National Grid all contractors were.laid-off. They would not return to transmission for two years. By the spring of 14

1976, the loss of contract trimming dollars had created tremendous deferrals, resulting in two separate tree-caused outages on'transmission lines from the Nine Mile nuclear facilities on the very same day. The nuclear plants were down f6r three days before they were brought back on line. Contracts were immediately executed to allow helicopter treatment of these lines and a number of other lines across the state. Ini total, 2,000 acres were helicopter treated that summer; however, the operation produced numerous complaints, claims, and lawsuits. The public outcry eventually drew the attention of the PSC and resulted in PSC Show Cause Order #27277 dated December 20, 1977. A condition of that Order was the development of a long-range right-of-way management perspective for all electric transmission. This order resulted in National Grid submitting its Transmission Right-of-Way Management Program to the PSC in May 1978. This Program was approved by the PSC on October 25, 1978.

Throughout the 1970's National Grid's right-of-way management philosophies had been evolving toward a more selective approach. Specifications had been revised, supervision augmented by hiring professional foresters, training programs instituted, and more sophisticated'planning procedures developed in an effort to maintain reliability in an environnentally'compatible manner. The ,Nine Mile outages simply accelerated the completion of that process.

Creating the System Forestry Department in the early 1970's, hiring additional foresters from 1974 to 1976, and centralizing the scheduling and budgeting functions within System Forestry staff in 1977, provided the opportunity for a full reassessment of vegetation management policies, procedures, and practices in 1978. It was recognized that while acceptable reliability goals were being achieved, the rights-of-way were not necessarily being managed on a cost-effective basis. While serious efforts had been made over the years to "get the rights-of-way in shape," no real preventative maintenance program existed. Budgetary considerations and limited spectrum herbicides resulted in lines that were partially maintained, many of which contained high populations of.

herbicide resistant'species. Then, in 1979, System Forestry presented senior management with a proposal to' put the entire transmission right-of-way system onto a cyclical preventative maintenance program. The program was calculated to maintain reliability and provide long-term economies while reinforcing the current'environmental ethic.

An eight-year' cycle was adopted after considering the overall condition of the rights-of-way and reasonable budget levels.' The proposals were incorporated into the electric rite filing for the first time in 1979, becoming the cornerstone to consistent program funding.

By 1980, the PSC had.enacted its Title 16, NYCRR, Part 84 rules and regulations formally' requiring all investor-owned 'utilities in New York to submit long-range right-of-way management plans for PSC approval.

The Selective Management Era: '.

The adoption of selective treatment practices and birth of integrated vegetation management philosophies beginning in'1978, define this period on rights-of-ways. It 15

includes the use of research and information technology systems to expand the knowledge and understanding of natural systems, together with the long-term effects and effectiveness of various management practices. Today, it incorporates the ecosystem itself as an integral component in controlling undesirable vegetation and reducing pesticide use, while preserving and enhancing environmental quality. The three treatment cycles used over the last 23 years are described below.

First Cycle: In response to the PSC's order for a long-range right-of-way management plan, selective maintenance policies were implemented for all new and existing transmission ROW's in 1978. An eight-year, cyclical approach was adopted, and by 1985, all rights-of-way had been treated at least once. In fact, some ROWs were actually treated more than once. While it may seem inconsistent that lines could be retreated in less than eight years, this was not the case. The maintenance schedules were developed around line design, right-of-way widths and easement conditions, conductor-to-vegetation clearances, and land-use patterns on a right-of-way. For example, an older line, on single wood poles in a residential area may require more frequent maintenance than another line on taller structures, through rural areas on wider rights-of-way. Specific maintenance schedules were based on a combination of chronological timing, annual right-of-way assessments, and inventoried site conditions.

As a result, the "eight-year cycle" became the skeleton upon which the maintenance plans were constructed, rather than becoming a rigid, inviolate time frame. The year 1978 was selected as the beginning of the era, because it was the first year under the new "selective transmission right-of-way management program," which included complete site inventories and centralized record keeping.

The goal of the first cycle was to "eliminate a major percentage of the undesirable vegetation, while retaining and fostering the growth of desirable low growing vegetation." The low growing species would provide natural competition for growing space, retarding the reinvasion of tall growing species going forward. The anticipated benefits were decreased herbicide use; increased crew productivity; improved wildlife habitat; aesthetics; and public, and regulatory acceptance. First cycle accomplishments were reported in 1989, when the approved "Transmission Right-of-Way Management Plan" was last revised and submitted for PSC approval. The success of these philosophies and practices are further reflected in the "Cycles and Trends" section of this document, which reviews the entire integrated management period from 1978 to today.

Significant mileposts of the first cycle included:

EPA suspension of 2,4,5-T in 1979 and its replacement with Garlon herbicides later that year.

Introduction of water borne, cut surface treatments in 1979 replaced oil based stump treatments. The effectiveness of these cut surface products resulted in reduced use of basal applications as well.

Computerization of the ROW management program in 1980 provided the ability to monitor trends in management practices, vegetation conditions, and herbicide use.

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Phase one of the National Grid's Yolney-Marcy 345 kV research project i- began in 1982 to look at environmental impacts and effectiveness of herbicide use following initial clearing.

'Cooperative efforts by National Grid to share important research and program results with the regulatory community enabled the company to negotiate the first statewide permit for utility application of approved herbicides in NYS DEC regulated wetlands.

Second Cycle: This cycle was reduced to seven-years, from 1986 to 1992. Once again, the time frame is considered a skeleton around which the overall program was developed.

The cycle was reduced in order to address continuing problems of off cycle, spot maintenance and to reduce the height of treated undesirable tree growth. This would help to further reduce herbicide use and improve selectivity with high-volume ground foliar applications.;

Through the first two cycles, undesirable tree densities were described as light, medium, or heavy. Light densities consisted of trees across the right-of-way ranging from 1 to 30% canopy closure. Medium represented stocking conditions from 30 to 65% and heavy included all tree growth conditions over 65% canopy closure. Integrated across the ROW were also light, medium, .and heavy densities of lower growing shrubs that were being retained, along with herbaceous communities. Strong biases toward shrub preservation continued to structure program goals into the late 1990's.

Important mileposts of the second cycle were:

Phase two of the Volney-Marcy 345 kV research project was designed and implemented to study effectiveness and environmental impacts of the various treatment methods available for maintenance, including such non-herbicide techniques as mowing, and grub and seed. This research, together with analysis of first and second cycle treatment statistics, began to clearly point toward selective foliar methods as the least impact, most effective choice.

While Round-up herbicide was introduced in 1985, its mode of action was different from the phenoxy herbicides and did not have an effective partner for tank mixing until 1987 when Arsenal herbicide was introduced. Accord herbicide replaced Round-up as the utility ROW formulation, providing utilities with the first product approved for use in seasonally dry wetlands.

Third Cycle: By 1992, the program was accomplishing its stated goals and exceeding expectations. Undesirable densities had continued to diminish so much that a new "very-light" density code was created in 1993. It describes sites with tall growing, undesirable species of 100 stems per acre or less. In addition to reductions in undesirable species, the right-of-way conversion to stable herbaceous and shrub communities enabled National Grid to move back to an eight-year cycle once again, from 1993 to 2000. In fact, by the end of the third cycle, desirable densities were becoming so heavy in many areas that they were "hiding" undesirable stems and keeping crews from locating them for treatment.

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U-During the third cycle, vegetation management theories about treatment methods began to shift. The Volney-Marcy research, other state and national research, and the efforts of utilities across the country continued to reinforce the effectiveness of selective foliar treatments. Borrowing concepts from aerial application that applied small quantities of a more concentrated mixture on the leaf surface, vegetation management professionals began to test these principles using low-volume, ground delivery systems. By reducing pressures and working closer to the target, applicators were able to "lightly wet" the foliage, rather than "wetting to run-off." This greatly reduced herbicide use, especially the over spray associated with high-volume, ground foliar applications. The development of new spray guns and nozzles enabled backpack treatments with even smaller quantities of herbicides and the refinement of tank mixes with newer products continued to push application rates and costs even lower.

By 1997, low-volume hydraulic treatments nearly replaced high-volume methods. The low-volume backpack approach proved more effective at controlling regrowth in areas that historically required stump treatments.

Important mileposts of the third cycle include:

Phase three of the Volney-Marcy research was approved to investigate long-term cost and effectiveness questions surrounding the latest products, delivery systems, and treatment methods.

A broad-based partnership, led by National Grid, was established to identify areas for continued research, and to share costs and benefits of this work.

New, low-volume techniques were introduced, tested, refined, and incorporated into treatment programs helping to reduce herbicide use requirements.

New herbicide tank mixes with Krenite and Escort herbicides were field tested, and effective mixes were incorporated into the program that reduce the "zone of effect" of treatment on desirable herbaceous and shrub understory species.

Results of three cycles and 23 years of Integrated Vegetation Management at National Grid will be discussed in the "Cycle and Trends" section of this document.

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CHAPTER 4 Cvcles and Trends The first treatment cycle effectively began in 1978 with the introduction of selective treatment methods, site-by-site prescriptions, vegetation management by professional foresters, and annual crew training to broaden their understanding of program principles, goals, and objectives. The first cy'cle to'ok eight years and included the'years 1978-1985.

The second cycle was reduced to seven years and included 1986-1992. The third cycle returned to an eight-year schedule and included the years 1993-2000. However, during this cycle, sub-transmissions located on narrow rights-of-way or in residential areas were scheduled on shorter five-to-seven year cycles.

Herbicide Usage:

During the 1960's and early 1970's, the tall growing vegetation on most rights-of-way was not effectively controlled. As a result, the treatment programs were heavily dependent upon helicopter and high-volume ground foliar applications. Brush densities were very high, often approaching '0,000io 20,000 stems per acre, and tree heights averaged 15 feet or more under the conductors. Helicopter treatments applied 4-6 gallons per acre (gpa) of concentrate. High-volume ground foliar mixtures were more dilute than aerial applications, but required as much as 300-400 gpa of mix or 3-9 gpa of; concentrate.

While the year 1978 represents the beginning of the selective, or integrated vegetation management approach, it also represents the transition year from the non-selective broadcast methods of the past. The last aerial treatments were c6nducted in 1982. ;The shift to prescriptive treatment required intense training and'field inspection. Crews needed to recognize and avoid "small and green" shrub species while targeting full coverage of tall growing tree species that were interspersed among the compatible vegetation.

Graph 1 and Table 1 quantify herbicide use over the last 23 years. Herbicide Herbicide Use - Gallonslacre of quantities are taken from annual use Concentrate reports, which were sent to the PSC as required by the 1977 show cause order for a long-range right-of-way 2.5 -. X. ;

management plan. They are expressed r

in gallons of herbicide concentrate'per-'

acre' for all treated acres. 1978 is'stated separately to serve as a baseline against -1978 1st 2nd 3rd Cycle Cycle Cycle which the program is measured, because' it represents both the earlier, non-' .Graph I selective era with its high densities, tall Cycle-to-Cycle Herbicide Use Reductions growth, and high-volume methods, while 1978 1stCycle 2nd Cycle 3rd Cycle still using less herbicide because of the GPA 3.66 1.46 0.84 0.59 new selectivity. %Reduction -60% -42% .30%

Table 1

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a-Graph 1 dramatically illustrates the reductions in herbicide use since 1978. The average use throughout the third cycle was 84% below the system use in 1978. Table 1 depicts cycle-to-cycle reductions, with first cycle reductions of 60% when compared to the baseline of 1978. The second cycle was 42% below first cycle requirements, while third cycle use dropped another 30% as low-volume foliar treatments were perfected.

Undesirable Densities:

Tall growing species that are capable of growing into the conductor area, commonly referred to as the "wire security zone," are considered undesirable species. The wire security zone is defined as a vegetation-free envelope around the conductor that should be achieved at the time maintenance is performed to the extent that easements, permits, and landowner constraints allow. The wire security zone requirements are discussed in detail in Chapter 7, section A. 3 of the Transmission Right-of-way Procedures.

Over the past two decades, the undesirable species list was primarily comprised of tall growing tree species. An effective management program aims to reduce the density of these undesirable species over time. As compatible ROW vegetation becomes more competitive and stable over time, an indicator of program effectiveness is a reduction in total ROW acres that require treatment from cycle-to-cycle. In Graph 2 below, treated acres are expressed as a percent of total ROW acres.

Graph 2 demonstrates how the Treated Acres as a Percent of All Transmission Right-of-way Management Acres Program has effectively reduced undesirable brush acres that require 100% 89%

treatment. While 89% of all ROW acres 90% - 83%

needed treatment in the first cycle, only 80% - 71%

71% had to be treated during the third 70%t cycle. This represents an 18% decrease 60% - IE in the treated acres and demonstrates the 50%>

increasing stability and competitiveness 1st Cycle 2nd Cycle 3rd Cycle of shrub and herbaceous communities in today's ROW's. Graph 2 Table 2 illustrates the shift in tree densities since the concepts and strategies of Integrated Vegetation Management (IVM) were first adopted. During the first cycle, 56% of all treated acres were either medium or heavy undesirable tree growth. Today, sites with medium density have been reduced by 38%, and heavy densities have been reduced by 68%. Additionally, these densities are generally found on sites that have a history of either non-herbicide or stump treatment.

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Undesirable Densities -Tall Growing Trees (As a percent of all treated acres)

Very Light Light Medium Heavy I st Cycle 0% 44% 37% 19%

2nd Cycle 0% 52% 40% 8%

3 rd Cycle 32% 39% 23% 6%

Table 2 In response to this reduction in undesirable densities, the new category "very light" was added in 1993. This density represents sites with 100 stems/acre or less. These conditions were so rare during the first two cycles that they were simply included with light acres. Today's very light conditions are found on nearly one-third of all treated sites, and very light and light densities combine to represent 71% of all treated acres.

Desirable Densities:

Since its inception, the Transmission Right-of-way Management Program has primarily considered woody shrubs to be desirable species. Herbaceous growth such as the ferns, goldenrod, berres, and other perennial broadleaf weeds and grasses have been considered incidental vegetation components of the right-of-way in the past, however, research has shown that herbaceous plants make a significant contribution to right-of-way species richness and diversity. They also contribute greatly tothe total competitiveness of low growing species found in the ROW, and are important factors in total habitat considerations.

Based on the work of Egler and the early PSC support for shrub' communities, a bias toward shrub dominance of the ROW has persisted in New York since the earliest days of the Program. More recently, theories on optimal shrub densities have begun to change.

For example, field observations of researchers have begun to indicate that as shrub densities increase beyond 70%, important songbird nesting habitat may be lost for both old field and shrub nesting species.

From the beginning, inventories have been designed to identify shrub density at the time of treatment and monitor trends toward increasing total'shrub cover. Consistent with these goals and objectives, desirable species have been described as woody shrubs and small trees that would not grow into the wire security zone and lead to an outage.

Densities have been reported in percent of canopy closure as follows:

none present (including open field)

light (I - 30%)

medium (30- 65%) '

.. *,heavy(65-.100%) .

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Table 3 illustrates the shift in shrub Desirable Densities -Shrub Species densities across the system since (As Cyclne 3rdlCcle Change selective IVM principles were first None 28% 27% -3%

reuto nLight 34% 24% -26%

adopted. We clearly see a reductionin Medium 21% 27% 26%

light densities over the years, while Heavy 17% 21% 25%

medium and heavy shrub conditions have increased by 25% or more. It is Table 3 important to note that these density classes are so broad that they may not fully represent the change in density that has occurred. For example, a change from 5% shrub cover to 25% shrub cover is a five-fold increase, but will continue to be reported as a light density at the time of inventory.

Cost Management:

Implementing a sound, integrated vegetation management program requires a higher up-front cost to effectively control taller, denser stands of undesirables and prevent or eliminate regrowth. However, once the undesirable stems have been brought under initial control, the right-of-way will stabilize into herbaceous plants and woody shrub communities that have been retained. This process is called the "Conversion Period" in the literature. The compatible communities then provide natural competition, slowing the invasion and redevelopment of taller growing undesirable species. Over time, a successful management plan will create fewer undesirable stems, require less herbicide, and cost less to maintain. The chart below illustrates changes in the average cost per treated acre, for all methods at National Grid from 1978 to 2000.

500. -& W ,:,j~~~:,> .:,vo; Cost 1 1' 0 Bt 0 0~ -,_ _

r__

01 _1 .1 _1 _01It ,- -

b co CD Co W co 0% > 01 016 Graph 3 The cost savings of the program have exceeded initial expectations. Treatment costs from 1998 to 2000 were lower than actual costs from 1978 to 1980 when National Grid treated with helicopter and high-volume ground methods. Allowing for inflation over the past 23 years, it is clear that the Integrated Vegetation Management approach that was implemented in 1978 has been highly successful in managing costs, while also reducing herbicide use and inhibiting tall growing trees.

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CHAPTER 5 Ecolotricall'v-Centered Veeetation Mana~yement Introduction - Integrated Pest Management The U. S. Congress defined Integrated Pest Management (IPM) under FIFRA, 7 U.S.C 136r-1, as "a sustainable approach to manage pests by combining biological, cultural, physical and chemical tools in a way that minimizes economic, health, and environmental risks." The definition recognizes IPM as a scientific methodology that has been developed with input from all sectors of society. Under FIFRA, risk reduction is the ultimate goal and guiding principle of IPM.

In 2000, New York State incorporated these philosophies into 6 NYCRR Part 325 when it defined IPM as "a systematic approach to managing pests which focuses on long-term prevention or suppression with minimal impact on human health, the environment and non-target organisms. IPM incorporates all reasonable measures to prevent pest problems by properly identifying pests, monitoring population dynamics, and utilizing cultural, physical, biological or chemical pest population control measures to reduce pests to acceptable levels."

While both federal and state regulations use the terms "cultural, physical, biological and chemical," neither establishes their definition. Drawing from IPM's agricultural model, examples of cultural measures might include crop rotation to minimize the risk of increased pest populations. Examples of physical controls include tillage or cultivation, and hand picking the pest. A classic biological control involves the introduction of a natural predator or vector to reduce or control the pest. Chemical controls are the use of pesticides.

In 1996, IPM Associates defined IPM as "a pest management system designed to provide long term management of pests, not temporary eradication of them," in their work "Introduction of Integrated Pest Management (IPM) for 'Urban' Landscapes," located on the Inter-et at www.efn.orn/ inmpa/ipmintro.html. They describe 1PM in broader terms*

than the classic agricultural definition. Their description includes:

a decision making process

intensive information management methods and systems

site specific prescriptive actions

a multiple methods approach

a core risk reduction strategy

cost effectiveness Integrated Pest and Vegetation Management on Rights-of-way in New -York IPM has its roots in agriculture, and a framework for the principles of IPM can be traced back to the 1940's and 1950's. As a result, the terminology and examples that are often used to describe key elements of a successful IPM program commonly draw upon this.;

agricultural model. However, it can be difficult to borrow "off-the-shelf' programs and 23

ideas from one discipline and apply them intact to another management system. Some modification or adaptation of terms is necessary, while still remaining faithful to the model and true to the intent of the regulation.

The introduction of the philosophies and principles of IPM into regulations for management of powerline corridors is a more recent phenomenon of the 1990's.

However, as described in Chapters 3 and 4 of this document, right-of-way managers in New York State have been applying the core tenets of IPM to electric transmission rights-of-way for much of the last quarter century. In fact, the model that has been evolving among right-of-way managers more closely matches the "Urban" model set forth by the IPM Associates, while remaining faithful to its agricultural roots.

For rights-of-way in New York, we began to see the first adaptation of terms related to IPM in the mid-1980's. It is difficult to describe the mighty oak or the sugar maple, which is the State tree, as a "pest" to a concerned landowner or citizens group. But oaks and maples are components of tall growing "vegetation," or pests, that are capable of growing into overhead transmission lines and causing outages. Thus the term "Integrated Vegetation Management" (IVM) was coined in 1986 to describe the management processes associated with electric transmission corridors.

Subsequently, the terminology has evolved into a "position paper" on right-of-way vegetation management for the members of the Environmental Energy Alliance of New York (EEANY). A copy of this paper, entitled "Applications of Integrated Pest Management to Electric Utility Rights-of-way Vegetation in New York State" is included as Appendix 3.

IVM for rights-of-way traces its roots to the 1970's when the adoption of selective management strategies aimed to reduce or eliminate the need for wide-scale broadcast herbicide treatments such as aerial spraying and high-volume ground broadcast. Today's strategies are based on science and have been developed with injput from society. The ultimate goal is risk reduction, while still including the "core" cultural, physical, biological. and chemical control methods. However, as the concept of IVM continues to evolve, it will perhaps be more accurately described as an "Ecologically-Centered Vegetation Management" philosophy that incorporates the basic tenets of IPM in a broader context, while better defining and describing the dynamics of ROW vegetation management.

The Ecological System National Grid's right-of-way management policy is to provide safe and reliable transmission of electric power to its customers in an economic and environmentally compatible manner. To accomplish this, each right-of-way manager applies a broad ecological overview to the principles of Integrated Vegetation Management.

Plant succession can be described as a process whereby a forest opening reverts from its bare ground state through time to an array of evolving plant cover types and 24

communities, until a forest ultimately occupies the site once again. Some stages of succession may be relatively stable for periods of time, and some community complexes may be more resistant to further invasion by trees than other communities over time.

Natural forces and disasters may interrupt this continuum, but on most sites the ultimate plant community will always be the forest.

Most transmission corridors cross a variety of land management practices and cover types, including areas of active management (e.g. cultivated fields, orchards, pastures, and the managed landscapes of homes and businesses), and areas of less active management (e.g. abandoned fields, shrub lands, and adjacent forest). At times, the activities of others will eliminate the need for ROW management intervention. At other times, it may increase the need for intervention. Typically, there are more acres of brush in the early stages of plant succession than there are acres that are actively cultivated or managed by others. However, it is the natural sites that offer the greatest opporiiunity'for management intervention to create a rich, diverse array of compatible species that can be relatively stable and resistant to new tree invasion, and provide the greatest ecological benefits.

The opportunity for conflict arises when tall growing trees and shrubs are planted in the, landscape or occur naturally through plant succession. When resurgent trees are allowed to grow into or fall on overhead transmission lines, a flashover and electrical fault to ground will occur, interrupting critical service and posing a risk to public health and safety. The sensitivity of the transmission system to tree outages that may occur under higher loading conditions was illustrated in 1996, when tree outages interrupted the Western transmission grid on twio separate occasions, causing blackouts throughout the Pacific Coast and Rocky Mountain regiorns.

Regrowth problems that arise from stump sprouts and root suckers after clearing have been explored earlier in this document;' No successful, economic alternative to herbicides has been developed that will prevent this reinvasion. At the same time, right-of-way managers have come to know that herbicides are simply one tool,'and that the successful program can reduce its reliance on herbicides overtimne. This is accomplished through successful management of the right-of-way ecosystem, as explained inthis chapter and in the "Cycles and Trends" chapter earlier in this document. Finally, managers have also learned that adherence to a well-planned cyclepof inspection and scheduled maintenance is essential to optimize the timing 6f herbicide treatments and to the effective implementation of a herbicide reduction strategy.

Field experience 'arid research has found that the "optimal" ROW vegetation condition is a blend of ferns,'herbaceous plants (forbs and grasses),'and shrib comrunitiesfThis rich, diverse blend of smaller plants and plant coniminities maximizes the competition for sunlight,'water, and soil nutrients that in turn tend to retard reinvasion and suppress tree seedlings in their understory for a number of years.: Such communities can also develop tight, dense root systems making it more difficult for some tree seeds to germinate and devel6p. A blend'of herbaceous and shrub communities also provides important habitat to a number of animals such as field mice, meadow voles, rabbits, and 25

a-deer which in turn feed on tree seeds and small seedlings. Seed predation and herbivory by small mammals has been demonstrated to destroy tens of thousands of seeds and seedlings per acre over a management cycle. This mixture of low growing ferns, herbs, and shrubs also provides nesting and other habitat features for a number of other species, including grass and shrub nesting songbirds, insects, and a host of other game and non-game animals.

In this ecological model, the ultimate control program is one in which vegetation itself, together with the entire ecosystem, resists tree invasion and reduces the need for chemical intervention. Treatments then become more and more selective, targeting the scattered trees and taller shrubs that escape competition and predation to eventually emerge above the canopy of the compatible communities. The optimal ROW management policy embraces these principles and practices, while applying the traditional IVM methods to achieve the system reliability and cost goals. This approach requires a full understanding of natural processes and systems that is based on science and research, balancing these with knowledge of land use patterns, individual landowner requirements, public perceptions, and regulatory constraints.

A Comparison of Historic Agricultural IPM to ROW IVM The application of traditional IPM definitions from the agricultural model IVM methods within the ROW might include:

Cultural methods: The ROW is converted from tree growth to a compatible use, through cooperative agreements with adjacent landowners to enable pasturing or cultivation, or Christmas tree production. It could also be converted to wildlife food plots or special habitat through partnerships with conservation and wildlife groups. In a more urbanized setting, cultural methods might include easement agreements that establish a managed landscape or even paving the ROW.

Physical methods: The use of traditional handcutting and trimming, as well as mechanized clearing such as mowing or grubbing. Physical methods that have been studied include the general use of fire for controlled burns, as well as "flame thrower" type equipment to destroy the cambium area of the tree with basal fire treatments.

Biological controls: The introduction of natural enemies. To date, forest and ROW management programs have been unsuccessful at introducing natural diseases or predators, such as insects, due to the difficulty in keeping the vector or predator within the bounds of the right-of-way. In addition, while some research exists on the naturally produced herbicides of some plants, known as allelopathy, many believe that the effectiveness of these natural herbicides in reducing or eliminating other species is small when compared to the forces of natural competition for sunlight and available soil nutrients. Except for limited work on the use of natural decay fungi for stump treatment, little field experience or research exists for developing either natural herbicides, or insect or disease pathogens for field application.

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Chemical controls:, The selective application of a number of herbicide products, mixtures, and delivery methods, wvith individual treatment regimens prescribed on a site-by-site basis. High-volume, broadcast operations have not been used extensively since the first cycle, when initial ROW reclamation efforts were completed. The near elimination of the site conditions that require high-volume treatments today is a testament to the success of ecologically centered-management that employs IVM methods.

A Comparison of IVIM to the Core Principles of Urban IPM In its "Introduction to IPM for .'Urban' Landscapes," the IPM Associates, Inc., set forth that "IPM in theory and practice is guided by an established set of principles." These principles describe IPM as:

an ecologically sophisticated management process

information intensive

employing all available pest control methods

mitigating negative environmental impacts'

requiring appropriate standards for pest control

emphasizing prevention of pest problems' promoting the use of methods that provide long-term pest control The IVM policies and practices for a Transmission Right-of-way Management Program incorporate these guiding'principles for "urban IPM" as follows:

1. IPM is an ecologically sophisticated mana'gement process.

This priniciple establishes that "iPM prograisutilize an &6ologicalapproachto pest inanagementthzatemploys extensive knowledge of individualpests'and their' relationshipwith their environment.' This holistic iiew of the pest'i anagement system 'is essential in managing'the variety offactors'that inJlueiece the deelofiment ofpestproblems." '

To achieve this,-the ROW manager must be familiar with the growth habits and differences of the multitude of tree and shrub' species encountered on the ROW, together with their relative stability or instability, and the species regrowth characteristics'. They must thoroughly understand the response of different species and communities to various management practices, ard they must know the ecosystem dynamics each community generates.' The ma lager must then balance these'values with system reliability requirements, operational constraints, social values, and public perceptions.

The sophistication and succe'ss of the'IVM approach has already been demonstrated.

This could not have been accomplished without a commitment to research that is designed to fill the gaps in our knowledge and understanding of natural systems, and the response of these natural systems to a variety of management alternatives. Over 27

a-the years, National Grid and the New York utilities have relied heavily upon research to expand their knowledge of natural systems and to base their management practices on science. As a result, they have become industry leaders in IVM research, completing more than 13 studies since 1974, at a cost of over $3 million. A summary of this research is included in Appendix 4.

2. IPM is information intensive.

The Urban IPM framework states, "IPMdecisions depend on detailed information about a variety of importantfactorssuch as: pest life cycles, site conditions where pests are located, the maintenance history of individualsites orfeatures,previously appliedpest control techniques, and the presence ofpredatory agents. An IPM program 's database is one of its major assets and requiresa collection and processingsystem so this information can be used effectively for implementingpest mnanagement activities,for evaluating the program, andfor developingprograms improvements."

The importance of information systems to facilitate the collection, reporting, and analysis of data in a successful integrated vegetation management program was recognized as early as 1980, when the Program was first developed. The information system was originally designed to capture and report data at the site level, while building hierarchical reports to the ROW, Region, and even System levels. This computer system became known as the Transmission Right-of-way (TROW) program. It provided a hierarchy of data that enables managers to readily analyze local, regional, and system data to determine species conditions, treatments and treatment response, costs, herbicide use, and effectiveness trends over the years.

While the system has been periodically updated to facilitate field collection and data processing, the data elements that are reported have remained relatively constant.

The essential field data includes site location, land use characteristics, environmental and public sensitivities, desirable and undesirable species conditions, past or present management prescriptions, treatment dates, and herbicide quantities. This information is carried from one cycle to the next and is regularly used to review and evaluate the effectiveness of management activities in meeting the program goals and objectives.

3. IPM employs all available pest control methods.

"The integrateduse of multiple management options is a key to cost-effectiveness of IPM. JVhile permissible pesticide use is minimized through development and application of otherpest management mnethods. In addition, careful evaluation and selection ofpesticide materialsis done to promote maximum utilization ofproducts that are least toxic to non-target organisms and the environment.

"Conventionalpesticide basedprograms have reliedprincipally on only one method of treatmentfor effective pest control."

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aWhile no effective alternative to herbicides exists for controlling undesirable, tall growing woody growth within utility rights-of-way once these species become established, a successful ecologically-centered management program that employs IVM methods will foster and encourage smaller, compatible plants and plant communities. These'desirable communities then become the primary non-pesticide management option for effectively reducing undesirable stem density. The ultimate control is a condition where the vegetation itself, together with the entire ecosystem seek to resist tree invasion through natural competition and predation, thereby retarding reinvasion and limiting the need for chemical intervention.

As undesirable stems begin to appear above the herbaceous or shrub layer, the ROW manager relies on regular field assessments and sound cyclical programming to optimize treatment schedules, and achieve maximum selectivity and effectiveness, while minimizing herbicide use and treatment costs. Once tall growing vegetation escapes the herbaceous and/or shrub layer, the ROW manager draws upon an array of treatment options, tailoring herbicide prescriptions to specific site conditions. On ROWs that have been converted to a relatively stable mix of smaller herbaceous and compatible shrub communities, herbicide applications will be highly selective; targeting low,densities of the tall growing species that are scattered among the compatible communities before they invade the wire security zone.

National Grid has actively workedwith manufacturers, industry experts, and research scientists since the 1970's to evaluate, test, and develop new herbicide products and delivery systems, and to understand their effects on desirable, natural systems. This program has a history of increased selectivity and continuous reduction in herbicide use. This has been accomplished by continually monitoring and testing herbicide products, mixtures, treatment methods and delivery systems, and implementing those methods that have reduced environmental risk. The result becomes an array of effective treatment methods and mixtures that can be tailored to specific site' conditions and that pose the least toxic risk to non-target communities and the environment. While the program continually evaluates new products and delivery systems, investigations of non-herbicide alternatives are ongoing, weighing their ability to eliminate and control undesirable tree growth against the requirements for reliability and cost effectiveness. Areas of active research have included hand cutting, mechanical mowing, and grub andwseed. Additional field plots were tested with fire (backpack flamnethrowers) and controlled burn. Data for sheep grazing has also been reviewed and discussed with researchers.

4. IPM mitigates negative environmental impacts.

"IPM minimizes pesticide use and other environmentally disruptivepest control treatnients to promote environmentalquality, preserve the naturalecosystem, and reduce undesirableeffects on non-targetorganisms."

The successful implementation of IVM strategies have converted the rights-of-ways to more stable herbaceous and shrub communities over the past 25 years and have 29

reduced herbicide use by 84% since 1978. Additionally, today's management costs are at their lowest levels ever. The establishment of compatible communities has further enabled the ecosystem itself to become the primary control mechanism. As a result, treatments today can be prescribed to maximize the use of low-volume, stem specific methods, and further maximize the retention of natural communities. In addition, buffer zones and non-herbicide methods are prescribed to protect sensitive resources.

The use of habitat destructive methods such as grubbing is avoided, and mowing is restricted to work areas, access routes, and conversion sites to the extent practicable.

5. IPM requires appropriate standards for pest control.

"IPMpromotes tolerance of non-damagingpest populations andappropriate thresholdsfor pest control that reduce unnecessary treatments. This enhances program efficiency and minimizes the application of undesirable treatments."

The National Grid Program uses regular field visits to audit and monitor crew performance and treatment effectiveness. This insures that all undesirable, tall growing stems that have "broke canopy" and emerged from the herbaceous or shrub layer, are controlled and resprouting is prevented. Small, undesirable stems that are suppressed within the herbaceous or shrub communities may remain unseen in the understory at the time of treatment, and yet succumb to natural competition or predation before emerging above the canopy.

While the Program's cycle length is broadly constructed around an eight-year cycle, individual cycles may vary from four to six years for lines in more sensitive areas, and up to eight years on other ROWs. Key factors in determining actual cycle length for a particular site or ROW include reliability requirements, construction and conductor clearance conditions, vegetation height and density, and visual and environmental sensitivity. Treatments are timed to minimize visual and environmental impacts, minimize long-term herbicide use requirements, ensure reliability, and maximize cost effectiveness. This is accomplished by scheduling treatments when most vegetation is within the optimal treatment height range for each right-of-way and before undesirable vegetation can grow into the "wire security zone."

The wire security zone is the vegetation free zone that must be obtained between the conductor and the top of vegetation at the time of treatment. The program also utilizes regular patrols and field assessments to monitor growth conditions and determine optimal timing for the next treatment cycle. Factors weighed in the scheduling decision include the heights and density of undesirables, undesirable re-growth patterns (e.g. stump sprouts and root suckering vs. seedling growth), age since last treatment, past treatment effectiveness, selectivity and herbicide use requirements, the impact of prescribed treatments on nearby desirable vegetation, and other factors.

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For example, a site or line that exhibits poor control and rapid regrowth after topping or trimming, or from stump sprouts or root suckers may be rescheduled on a shorter cycle. "Short cycling" in this example may actually treat smaller sized undesirable regrowth than waiting for the "normal" cycle, effectively reducing herbicide use with less impact on desirable vegetation and greater long-term effectiveness. The treatment cycle for another line may be extended if the average height of target vegetation is smaller than the optimum treatment height, or if the line has taller construction and the target stems are light and scattered with adequate wire security zone clearances. The lengthening of the cycle in these examples will actually reduce the herbicide requirements over time.

While National Grid's current cycle represents one of the longer treatment cycles in the State, the use of selective, low-volume treatments has enabled the Program to minimize costs, maximize effectiveness, and provide one of the lowest application rates in the State.

6. IPM emphasizes prevention of pest problems.

"Effective utilization of IPM design and site modification practicesreduces the need for pest control treatments, helping to minimize pesticide use requirements and making resources availablefor other maintenancepriorities. In turn, these benefits promote environmental quality andfacilitateimprovements in the aesthetic quality of the resourcesystem. It also reduces life-cycle maintenancecosts of specific landscapefeatures."

An effective IVM program strives to reduce or eliminate those site conditions that require the use of high-volume broadcast treatments over large segments of the entire right-of-way. This is accomplished through implementation of selective treatment practices that will effectively control undesirable tall-growing stems while fostering a rich, diverse, competitive mix of herbaceous and woody shrub plants and communities. The most successful programs modify their management practices to encourage this ecosystem design, and strive to reduce and minimize adverse impacts to the natural system itself.

IVM on New York's rights-of-way has been a quietly evolving success story that can be directly attributed to the adoption of long-range management plans in the late 1970's and early 1980's. These plans have been designed to accomplish this ecosystem approach and:

foster and encourage the development of low-growing, compatible vegetation

utilize site specific prescriptive application methods

,; adhere to sound cyclical programming guidelines

receive consistent funding Most high-volume broadcast treatments have been replaced by selective, low-volume methods as the rights-of-way have been converted from a medium to dense tree condition into relatively stable communities of compatible species. For example, the 31

last use of helicopter application on the National Grid system occurred in 1982 and very few lines or sites today have undesirable densities that require extensive high-volume broadcast treatment.

Moving forward, the vegetation management practices will strive to preserve the ecological quality that has been achieved; minimize adverse impacts on desirable communities and cover types; and prevent or avoid soil disturbances that may lead to an increased erosion potential or seedbed preparation, including re-invasion by undesirable tall growing species. For example, improvements to clearing and tree removal equipment are enabling a shift toward tracked excavators and tree harvesters for danger tree removal in some areas. This equipment reduces the ROW scarification and disturbance along the edge that may be caused by turning when conventional bulldozers with brush rakes are used for danger tree removal operations.

At the same time, there are clearly instances when the use of conventional skidder buckets and bulldozers represent the most effective option for danger tree removal, and seeding and mulching may be required to mitigate disturbance.

The implementation of a tree replacement program in 1998 has helped to soften the need to remove problem trees from the landscaped setting, enabling cooperation with property owners to maintain important aesthetics and landscape values while reducing future maintenance problems and increasing reliability.

7. IPM promotes the use of methods that provide long-term pest control.

"Like IPMpractices thatprevent pest problems, those mnethods which provide long-term pest control benefits also enhance program efficacy, proinote environmental quality by reducing the needfor undesirabletreatments such as pesticide use, and enhance the aesthetic quality of the resourcesysten? components."

'Conventional pesticide-basedmanagement programsprovide only short-tennpest control and, in the long tern, potentially involve negative impacts onl program efficacy and environmentalquality.

The transition from high-volume broadcast methods designed to eradicate all woody brush to selective treatments of isolated, scattered or light individuals or clumps within the right-of-way landscape, have in fact provided the long-term control benefits described above. These practices have led to continued reductions in undesirable species densities from cycle to cycle, and promoted continued reductions in herbicide use and costs while greatly enhancing system reliability.

The success of today's program is reinforced by a number of research projects that found the right-of-way to be a biologically rich, diverse array of plants, birds, and small animals that exist because of past treatment methods. In fact, with the continued conversion of old farms into forest lands, the utility right-of-way has become one of the last remaining areas of shrub habitat in New York today.

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Summary and

Conclusions:

The right-of-way management policies and procedures, first implemented in 1978 and continually refined over the past two decades, have evolved into a fully integrated vegetation management program. National Grid has relied upon both the science and art of ROW management, striving to become a recognized industry leader in right-of-way management practices. This has been accomplished through active participation in research and the continual review and implementation of recognized best management practices.

The success of the Program in achieving herbicide reduction strategies while improving the quality of the ecosystem is clearly documented, as is the ability of the Program to effectively reduce maintenance costs and improve system reliability performance.

National Grid has been a statewide leader in the development and successful implementation of an ecologically centered management philosophy that truly embraces the principles and practices of Integrated Vegetation Management.

Additional proof that today's vegetation management practices and procedures are industry best practices is illustrated in the adoption of similar management principles and philosophies by the top performing utilities nationwide, together with the incorporation of these philosophies into a national right-of-way management policy. One of the best examples for the national adoption and inclusion of these principles has been the development of the Pesticide Environmental Stewardship Program (PESP) by the Edison Electric Institute Vegetation Management Subcommittee, a copy of which can be found in Appendix 5. The strategies of this PESP have in turn become the cornerstone for a voluntary partnership between utilities nationwide and the US Environmental Protection Agency on integrated vegetation management. The IVM position paper for the New York utilities played an integral part in the development of these national strategies.

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CHAPTER 6 Transmission Right-of-wav Management Pro2ram:

Goals. Obiectives, and Strategies:

Right-of-way Vegetation Management Policy National Grid's Transmission Right-of-way Management Program is designed to provide'

-for the safe, reliable transmission of electric energy in an economically efficient manner that protects the environment and is consistent with sound integrated vegetation management practices and philosophies. The Program shall support compliance with ISO 14001 standards and incorporate appropriate industry best management practices into daily operations, while ensuring that the Company remains a good steward of the environmental resources it manages. The Program shall incorporate good customer and public relations, and continually seek sound, practical avenues for improved customer relations and public education.

All right-of-way vegetation is to be maintained in a condition that strives to prevent interruptions caused by trees and tall growing shrubs. In addition, the natural and man-made ROW features are to be maintained in a stable condition that assures environmentally compatible access for routine and emergency line operations. This will continue to be accomplished through routine monitoring of right-of-way conditions, sound vegetation management planning, and implementation of the appropriate vegetation control techniques. The Program shall also seek continuous improvements in its state-of-the-art management systems and treatment methods.

Rights-of-way Included in the Program National Grid shall include all electric sub-transmission, transmission, and bulk transmission (23kV and above) within this long-range Program. In addition, while rights-of-way constructed since the mid-1970's may have been subject to the environmental siting and construction provisions of Article VII of Public Service Law, including special clearing and construction requirements, the Company has actually incorporated future maintenance activities into the provisions of this Program. This incorporation enables unif6rm and consistent application of the same guiding policies, procedures, anid practices to all rights-of-way regardless of when they were constructed. Special environmental terms and conditions that 'were established for a particular line or site through the Article VII process, and are relevant to protecting the resource today, have been included in Appendix 1, and are included for future maintenance consideration.

The provisions of this Program shall also be incorporated into gas transmission rights-of-way activities when the occasional use of herbicides becomes necessary to control undesirable woody growth that cannot be rnanaged through regular mowing or when performing activities related to environmental protection or permitting. During discussions with PSC environmental staff, it 'wasagreed that field inventories are not required for spot or occasional herbicide applications on gas facilities. A listing of Article VII gas transmission rights-of-ways is provided in Appendix 2, including 34

identification of any special environmental protection measures that may have been established for these ROWs.

Cycle Length Even though the company has exceeded its original vegetation management goals of improved reliability and habitat while managing cost and decreasing herbicide use through the first three cycles, continuous improvement and enhancement shall remain a top priority. As introduced in the second and third cycles, selected transmission facilities in visually sensitive areas on narrow corridors or through predominately residential areas, will continue to be scheduled on shorter cycles of four-to-six years. Wide corridors through predominantly rural areas where vegetation has successfully been maintained on a longer cycle will continue to be scheduled on no more than an eight year cycle. Results of treatments will continue to be assessed with respect to cycle length and overall Program goals.

Reliability Improvements and Program Enhancements Trees and tree limbs falling onto the electric system from beyond the right-of-way edge are the main causes of tree outages. Prior to 1995, danger tree removal efforts focused primarily on trimming and removing scattered edge trees rather than extensive widening.

Beginning in 1995, the reduction in undesirable stem densities created through the Integrated Vegetation Management (IVM) program began to generate significant cost savings. These savings have been reinvested in an expanded danger tree removal and widening program. Today's widening effort focuses on high-risk and critical segments of the transmission asset. This effort has reduced the probability that a tree will reach or hit the transmission system when it falls and has helped significantly reduce the number of tree-caused outages. While the adoption of IVM practices has been the greatest contributor to the success of today's Transmission ROW Management Program, problems with shrub retention practices have gradually developed. In the earliest days of the program, the regulatory community strongly supported the premise that dense, woody shrub communities provided the ideal landscape for ROW management. Additionally, crew training was simplified to target "big and green" trees while retaining "small and green" shrub communities. The long-range Program itself embraced these concepts.

However after more than two decades, some of these "small" shrubs have become too tall in some areas, invading the mid-span "wire security zone." The shrub community may then hide or mask undesirable tall growing species from the sight of treatment crews. As shrub communities become denser over time, they restrict access to large areas of the right-of-way, further increasing the chance of skips or missed stems during treatment.

Shrub intrusion into the wire security zone reduces the vegetation free space between the conductor and brush. This increases the risk that as a tree emerges above the shrub canopy, or "escapes," the stem can quickly grow into the conductor area and cause an outage. In the last decade, this masking of undesirable trees by the shrub community has been the cause of every tree outage originated from a tree growing into the lines on either the 115 kV or the bulk transmission systems.

35

This revision to the Transmission ROW Management Program emphasizes the need to modify the philosophy that dense shrubs create the ideal ROW condition, and to introduce elements of the '"wire zone/border zone",concept first proposed by Bramble and Byrnes in their Gameland's 33 research in central Pennsylvania. The "border zone/wire zone" approach encourages a herbaceous condition under the conductor: The Company through this revision proposes to adopt a modified "border zone/wire zone" approach to managing its ROW's. The modified approach will target removal of certain tall growing shrubs in the wire zone while continuing to encourage low growing shrubs and -

herbaceous species in the wire zone. The detailed list of undesirable and desirable species to promote in the wire and border zones of the ROW are presented in Chapter 7.

As applied here, a modified "wire zone/border zone" will encourage a mosaic or blend of

herbaceous species with smaller shrubs that may exist in the site and still be compatible with the height and reliability requirements of the wire security zone. This mosaic will strive for a maximum shrub density on most sites of about 70%. This will facilitate crew access to the under wire area and increase treatment efficiency, while still maximizing habitat and environmental values, and minimizing herbicide use requirements over the life of the right-of-way. While the lower profile of some lines or sites may.require a predominately herbaceous wire zone, other lines or sites with taller design may tolerate a dense shrub condition. Where shrubs have already invaded the wire security zone, they will be selectively removed following the appropriate selection criteria defined in Chapter 7, Section F "Implementing the modified 'Wire Zone/Border Zone' Concept,"

and Section G "Definitions and Criteria of Vegetation Management Techniques" of this document.

Since shrubs are generally taller than most herbaceous communities, the competitive value of shrubs generally tends to be higher as well. However, a ROW dominated by shrubs can create access, reliability, and treatment problems as discussed above.

Research has shown that shrubs provide maximum competitive value along the edges of the ROW, nearest the seed source. At the same time, researchers from the SUNY College of Environmental Science and Forestry (ESF) have identified the richness and diversity of the herbaceous communities as well, including finding more than 300 total species on the ROW. That study found 50 different grass species, together with 160 herbaceous, 15 ferns, 40 shrubs and 30 tree species in a single 15-mile section of a ROW near Rome; N.Y. This, together with other studies suggests the importance of these other, non-woody species in a fully ecological approach to vegetation management.

In the ESEERCO Report EP 85-38 entitled "ROW Vegetation Dynamics Study," which was done in the Hudson Valley, researchers identified the important roles of both herbaceous and shrub communities in maximum seed and seedling predation. That study found that white-footed mice contribute to heavy seed predation in shrub communities while the meadow vole contributes to predation of tree seedlings after germination. Field mice were primarily residents of shrub habitat, while the voles were found in herbaceous

m habitat. As a result, the Company believes that a blend of herbaceous and shrub communities may provide the optimal blend for predation.

Recent field observations by researchers investigating nesting success of field and shrub nesting songbirds within the Volney-Marcy ROW suggested an optimal blend of shrub and herbaceous communities of approximately 30-70% shrub cover may maximize the nesting success of shrub nesting songbirds within the right-of-way. Shrub densities above 70% may actually reduce nesting success for some shrub nesting species by increasing nest predation, while densities below 30% may tend to favor grass nesting bird species. When applied to the wire zone a mosaic of herbaceous and shrub communities could increase plant diversity and benefit wildlife, and while also improving crew access, reducing skips and eventual escapes, and improving reliability.

Looking ahead over the next decade, the long-range Program will continue to strive to:

minimize herbicide use

control costs

continually improve worker and emergency access

enhance system reliability performance

control regrowth and invasion by of undesirable species

reduce undesirable densities

implement an effective wire zone/border zone approach for appropriate mid-span areas

manage for an optimal shrub-herbaceous mosaic across the ROW

enhance customer and public communication and education

meet or exceed all regulatory requirements 37

A. Goal: To manage the right-of-way in a manner to assure the integrity of the transmission facility.

The goal of assuring the integrity of the transmission system encompasses the long-term stability of right-of-way vegetation and the interaction of vegetation on system reliability. It also incorporates the requirements for ease of access by maintenance or emergency response crews, environmental stability of the land resource, and reporting adverse use.

1. Objective: Sustain the long-term stability of desirable plant com-munities'across the right-of-way mosaic, and use natural interference and predation to maintain or reduce the density of undesirable, tall-growing free species. Seek to maintain undesirable species densities predominately within a range of very light to light density.

All vegetation maintenance activities shall be completed in a manner that effectively controls regrowth, while striving to minimize herbicide use. Treatments shall minimize adverse impacts to adjacent compatible vegetation and prevent damage to environmentally sensitive resources.

.. .. 1 ... '

Strategy: a. Apply sound IVM principles to foster and encourage the development and expansion of a relatively stable mix of herbaceous and shrub communities within the ROW, and to selectively treat undesirable vegetation.

b. Use site-specific prescriptive programming of proven, effective control techniques; employ properly trained and certified personnel, and rimaintain appropriate monitoring systems.

2. Objective: Continuously improve electric system reliability by reducing the risk of tree caused interruptions from trees growing into the wire security zone from beneath the conductor.

Strategy: a. Apply the "wire zone/border zone" principles at appropriate mid-span areas, where the mature height of

shrubs or shrub communities may grow into and significantly reduce the wire security zone clearances. The wire zone/border zone methods shall be selectively applied to sites or lines where tall growing shrubs increase the risk of a tree caused outage. These sites shall be managed as to maximize their conversion to a stable mosaic of herbaceous and smaller shrub communities.

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- a-

3. Objective: Continuotfsly improve system electric reliability by reducing the risk of tree caused interruptions from trees falling onto the transmission lines from beyond the ROW edge.

Strategy: a. Monitor transmission edge conditions and system performance to identify potential high-risk facilities, and widen and remove the danger tree edge to the extent permitted by existing easement and landowner agreements.

4. Objective: Improve and maintain clear access routes along the ROW to all electric and gas infrastructure to facilitate routine and emergency vegetation management and transmission line operations.

Strategy: a. Maintain all existing access routes and travel paths keeping them free of all woody growth, and establish a 15-foot wide access route to all electric tower sites.

b. Utilize the wire zone for the travel path wherever possible in an effort to improve conductor-to-vegetation clearances.

c. Improve structure access by increasing the work zone at the base of each electric structure to a 15-foot radius that is free of woody growth.

d. Remove vines and vegetation growing on the electric and gas structures at the time of routine maintenance operations.

e. Repair existing access roads when erosion threatens future accessibility and environmental quality.

f. Periodically establish permanent access roads into remote or difficult access areas to improve working conditions for day-to-day and emergency line operations.

g. Maintain or install cross-drainage devices, swales, ditches, and other improvements to prevent water damage to access routes, facilities, and other environmental features.

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.5. Objective: Work with adjacent property owners to restrict adverse ROW uses and exercise control over vegetation growth, access, erosion control, and all other activities that could effect reliable transmission service.

.Strategy: a. Encourage fee ownership of all 115 kV ROWs and above, and obtain easements for existing ROWs when it is determined no easement exists.

b. Promptly report encroachments, dumping, and other adverse use conditions identified through routine patrols and monitoring activities to Security, Environmental Affairs, Right-of-way, Engineering, and other departments as required.

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a-B. Goal: To manage the right-of-way vegetation in the most cost effective manner commensurate with other right-of-way management goals.

The goal of economic vegetation management is dependent upon the principles of sound, ecologically-centered maintenance to optimize natural ecosystem controls, maintain environmental quality and respond to social sensitivities, while reducing undesirable densities, improving worker efficiencies, and providing effective cost controls. The goal is also accomplished through periodic field assessments and optimizing the treatment schedule, and through the ROW inventory process and close supervision of management crews to assure the maximum use of prescriptive, stem specific treatment methods. Maintaining good access further helps to reduce costs by improving crew movement through the shrub communities and enhancing productivity. Costs are monitored by SystemlDivisional Forestry.

1. Objective: Identify and utilize the most cost effective vegetation management techniques.

Strategy: a. Remain an industry leader in the development and implementation of an ecologically-centered maintenance program, stay abreast of the most recent industry research, and incorporate recognized industry best management practices.

b. Work in accordance with all safety, environmental, and public constraints.

c. Utilize crew training, field assessment and monitoring of treatment efficacy to assure site-by-site prescriptive assignment and completion, and accurate reporting of vegetation management activities.

d. Use the field inventory and work completion report to establish metrics for evaluating costs, treatments, herbicide use, and efficacy.

2. Objective: Establish and maintain cost-effective treatment schedules for each electric ROW.

Strategy: a. Maintain "ROW Master Schedules" for each cycle to identify the optimum schedule year for every ROW within the overall cycle.

b. Shorter cycles (e.g. four and six years) may be established for ROWs that follow highly visible highway corridors, or 41

- Ion lines passing through predominately residential areas

-that require more selective or more frequent trimming and non-herbicide methods.

3. Objective: Establish and maintain cost-effective treatment schedules for each gas ROW.

g. . M a n I . . ie. r.. -o .b. i.

Strategy: 2. -Maintain gas line rights-of-way by mowing.

Strategy: b. Incorporate the appropriate selection criteria and best management practices for herbicide application used on electric ROWs .to gas ROWs when occasional or spot treatment is required to control undesirable woody growth not controlled by mowing.

4.. Objective: Keep sufficient records to monitor ROW conditions, including long-term density trends for desirable and undesirable vegetation, herbicide use, and cost effectiveness.

Strategy: a. Continue to use the Transmission Right-of-way (TROW) computer program, which was developed during the first maintenance cycle and then enhanced in 1993 and again in 2000, to record and monitor costs, production, and performance; and also to schedule completions and monitor herbicide usage.

b. The system itself will continue to be measured against information technology improvements to continually provide essential information and data requirements for program analysis.

c. Compile and provide standardized reports to meet the PSC and the Department of Environmental Conservation (DEC) annual reporting requirements.

d. Utilize the historic reporting capabilities of the system to identify and share program performance, results, and success with regulators, researchers, and other vegetation management professionals through regional and national conferences and workshops.

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C. Goal: To manage the right-of-way vegetation in a manner that continues to encourage the development of a rich, diverse blend of stable herbaceous and compatible shrub communities, and to maximize the benefits of the total ecosystem in resisting tree invasion.

The goal of managing right-of-way vegetation to encourage diversity and stability applies a broad ecologically-centered overview to the principles of IVM, to create and maintain a mosaic of compatible, low growing plant communities. This mosaic in turn provides the optimal condition to resist reinvasion by undesirable vegetation, and maximize access for routine and emergency vegetation management and line operations. It facilitates site-specific prescription and selective application of the appropriate IVM principles and strategies in a manner that effectively controls undesirable trees and manages tall growing shrubs, while minimizing impacts on desirable shrubs and herbaceous species.

1. Objective: Maximize the competitiveness and benefits of various low-growing plant communities.

Strategy: a. Apply site-by-site prescription of vegetation management methods and selective application of approved herbicide products in a manner that effectively eradicates undesirable, taller growing species and prevents their re-growth from stumps and existing root systems.

2. Objective: Better understand the ecosystem dynamics of IVM, the response of desirable and undesirable components of the ecosystem to various management methods, and identify and examine data gaps in the knowledge base.

Strategy: a. Remain abreast with the latest research developments into the environmental and ecological benefits and impacts of various herbicide and non-herbicide treatment alternatives, and strive to remain an industry leader in vegetation management research and expertise.

b. Actively seek strategic partners in the development and completion of research initiatives to equitably share the benefits and economic burden of research with all parties.

c. Publish, disseminate, and share results and experiences for peer review.

43

3. Objective: Improve crew identification of shrub and small tree species that are capable of invading the wire security zone or otherwise interfering with reliable operation of the facility.

Strategy: a. Retrain field crews and supervision in shrub identification and mature shrub heights.

b. Train crews to recognize mid-span clearance conditions and apply selective clearing and treatment practices to those mid-spans and species that will invade the wire security zone at an early stage.

c. Encourage the development of smaller growing, stable herbaceous and shrub communities at an early stage in order to minimize future herbicide use requirements.

4. Objective: Continue a core pesticide reduction strategy to reduce long-term herbicide use requirements.

Strategy: a. Actively seek and test new products, treatment methods, and delivery systems to provide greater environmental compatibility, reduced environmental risk, increased public and worker safety, while meeting or exceeding system reliability and effectiveness requirements.

b. Utilize test plots, field studies, industry workshops, research and other sources to keep abreast of products, treatment methods, and delivery systems.

c. Optimize the selectivity of all herbicide treatment methods so as to reduce the gallons per acre use requirements and minimize the "zone of effect" on adjacent shrub and herbaceous vegetation.

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W-D. Goal: To maintain the environmental quality of sensitive resources and areas of the right-of-way.

The goal for maintaining environmental quality encompasses the way in which the program is administered and the vegetation is managed. It requires that the program and its related activities are applied in a manner that is compatible with sensitive resource requirements such as areas of high visibility, sensitive wetland or aquatic resources, endangered species or unique cultural resources, and similar significant resources.

1. Objective: Foster and maintain visual screens of naturally occurring compatible vegetation at locations with high visual sensitivity.

Strategy: a. Foster buffer zones of natural low-growing vegetation at high use road crossings or other areas of high public use sensitivities. Manage the height of vegetation in these buffer zones in such a way as to assure transmission line reliability and wire security zone requirements.

b. The trimming and topping of tall growing trees may be used to satisfy the aesthetic requirements when compatible shrubs and small trees are absent. This is the least desirable screening method and the cost benefit of removal and replacement planting will be considered when trimming costs become excessive or create a potential public safety risk.

c. Undesirable vegetation will eventually be removed and converted to more compatible species to fulfill the screening requirements up to the limits of the easements.

2. Objective: Protect sensitive aquatic resources from the adverse impact of maintenance activities, i.e. herbicide contamination, erosion, or physical degradation.

Strategy: a. Maintain buffer zones of compatible low-growing vegetation at sensitive aquatic resources, including lakes, ponds, and streams.

b. Utilize highly selective, stem specific treatments within these buffers together with herbicide products that are 45

specifically approved for ditch bank, stream bank, or aquatic use.

c. Employ non-herbicide management methods within the buffer zone when a risk of contamination exists.

d. Obtain permits from the DEC as required for herbicide application in State regulated wetlands and wetland buffer zone areas. Utilize geographic information system (GIS) or other suitable mapping capabilities to provide an annual DEC submittal of lines and wetlands to be treated.

Maintain regular communication with the affected DEC departments.

e. Provide each county Department of Health (DOH) with an annual schedule and map of proposed treatment areas, in order to identify public drinking water resources that may be within or adjacent to the right-of-way. Also provide a list of treatment methods and herbicide products to be used.

Work with the county DOH director/personnel to appropriately avoid or minimize potential adverse impacts.

f. Identify private drinking water supplies within or immediately adjacent to the ROW through the field inventory-process, and establish appropriate buffer zones to maintain and protect water quality.

g. Conduct all treatment activities adjacent to sensitive aquatic resources to maximize the retention of compatible shrub and herbaceous communities and reduce or eliminate the risk of erosion.

3. Objective: Work with appropriate state, federal, and private agencies to identify and protect known populations of endangered species resources; understand the risks of vegetation management activities on the species; and prevent incidental damage or take.

Strategy: a. Provide the DEC, by March 31of each treatment year, through the Natural Heritage Program, with an annual GIS or other suitable map submittal that identifies the location of various ROWs scheduled for routine maintenance each year.

b. Use information provided by the DEC and the Natural Heritage Program to identify known locations of New York 46

U-State or federally listed threatened and endangered species in proximity to scheduled activities.

c. Act as good stewards of the resource by collaborating with the DEC Endangered Species Unit to review and understand the risks and benefits of vegetation management activities on existing threatened or endangered species populations.

d. Communicate special treatment requirements and treatment timing to field supervision and crews, and implement all reasonable measures necessary to protect the resource.

47

E. Goal: To manage the right-of-way in harmony with compatible multiple use practices, including agricultural, recreational, industrial, residential, and wildlife uses.

This goal acknowledges multiple occupancy of the rights-of-way where such use is consistent with Company use and joint occupancy will not, in the Company's judgement, adversely affect the rights of adjoining landowners or occupants.

Multiple use encompasses all uses of the right-of-way including the primary use, which is transporting electric energy or natural gas. Right-of-way uses are grouped into human land use and natural land use. Human land use includes residential activities, commercial, industrial, agricultural, highway, recreational, etc. Natural land uses include environmentally sensitive areas such as wetlands, streams, significant habitat, and less sensitive woodland and brush land areas.

1. Objective: Minimize and discourage incompatible uses of the right-of-way to the extent practicable.

Strategy: a. Identify uses that are not compatible with the safe operation of the line through routine patrols and monitoring, including such activities as encroachments of buildings, structures, and certain adjacent construction activities, as well as logging or removing edge trees.

b. Install appropriate gates and barriers where they are likely to be effective and are needed to discourage unauthorized uses such as vehicular and ATV access that may threaten the integrity of the right-of-way or the environment by damaging access roads, culverts, stream fords, and desirable vegetation.

c. Notify the Environmental Affairs, ROW, Security, and Law Departments upon identifying unauthorized use such as trespass and dumping. Coordinate with these departments and, where possible, assist adjacent owners to implement reasonable efforts to post and/or discourage these unauthorized or incompatible use and activities.

d. Employ reasonable means to educate, notify, and inform the public concerning the risks and impacts of adverse use. Seek prosecution of known or suspected violators.

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CHAPTER 7 Transmission Ripht-of-w av Procedures A. -Identification of ROWs Recommended for Treatment

1. Electric Operations Patrol National Grid's Electric Operating Procedure (EOP) 211 establishes procedures for transmission line patrols. In accordance with this procedure, Regional T&D personnel complete an aerial patrol of the entire system annually, and report conditions such as "broken or flashed insulators, towers, or poles; leaning, broken, or damaged crossarms; burned or frayed conductors; and general conditions of the right-of-way." Unusual ROW vegetation conditions, including insufficient tree clearances that are observed during these patrols, are reported to the Divisional Forestry personnel. Unauthorized dumping activities are reported to the Environmental Affairs, Law, and Security departments.

Comprehensive foot patrols are completed on a five-year cycle with 20% of the system completed each year. Once again, conditions that are within the responsibility of the Forestry personnel, such as unusual tree or vegetation conditions, or erosion and access problems are reported to the Division Forester for inspection and implementation of the appropriate corrective action.

2. Division Forester's Assessments In addition to the routine patrols that are completed by the local T&D departments, each Division Forester conducts periodic right-of-wvay assessments of all transmission lines within their respective territorial responsibilities. The general purpose is to monitor right-of-way conditions so as to protect the lines from interruptions caused by trees and tall growing shrubs. Any other environmental impacts, such as unauthorized or destructive use, are noted. These assessments can include helicopter or ground review processes. Annual helicopter assessments are normally scheduled during the spring to mid-summer periods as needed to identify critical electric line mid-span and danger tree conditions, and/or to review completion of the previous year's work.

The purpose for the Forester's assessment is to:

review the results of the previous year's work and carefully check for vegetation, herbicide, and treatment effectiveness;

review the ROW at about mid-cycle to assure timely reschedulifig of the next treatment and to look for "escapes" or "misses;"

i;confirm maintenance priorities of lines scheduled for the iext year;

. assure that potential trouble spots, identified by,other sources, are reviewed by;a qualified vegetation manager; and

. assure that ROWs requiring spot work or danger tree removal are also reviewed and prioritized.

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- s

3. Wire Security Zone-Electric Clearance Requirements The reliability requirements for vertical tree clearances (below the conductor) and horizontal clearances (beside the conductor) are also contained in EOP 211. The tree clearance requirements for routine, prompt, and emergency action are defined below.

Priority A: As soon as practicable to ensure public safety and reliability Optimal 1Free Clearance Voltage ROW Width Lateral* Vertical 23 to 46 -50 18' or less 9' or less 69,115 75 20' or less 10' or less 230, 345 75 25' or less 12' or less Priority B: Scheduled before next growing season Optimal TIree Clearance Voltage ROW Width Lateral Vertical 23 to 46 50 19'- 25 10'- 13' 69, 115 75 21'- 28' 11' - 14' 230, 345 75 26' - 35' 13'- 17' Priority C: Scheduled next regular treatment cycle Optimal ITree Clearance Voltage ROW Width Lateral Vertical 23 to 46 50 26'- 38' 14'- 18' 69, 115 75 29'- 42' 15'- 19' 230, 345 75 35'- 49' 18'-22'

Note that the lateral clearance requirements are based on the optimal right-of-way width requirements for various voltage classes. On a site-by-site or ROW basis actual ROW width, easement restrictions, or landowner constraints may restrict the minimum clearances that can be actually achieved. More frequent review and/or maintenance may be required in situations where minimum requirements cannot be achieved.

The "wire security zone" is a vegetation-free envelope around the conductor that should be achieved at the time maintenance is performed. The following wire security zone standards have been established for different voltage classes considering the tree clearance requirements established under EOP 211 described above; as well as normal tree growth conditions, cycle length, the greater 50

variability of mid-span sag conditions of higher voltages, and peak operating load' requirements.

The wire security zone clearances that shall be achieved wherever practicable, at the time of maintenance or clearing are:

Wire Security Zone Distances Sub-transmission - feet -

23, 34.5 46 kV 15' Transmission 69,115 kV 20' Bulk Transmssion 230, 345 kV 25' B. Procedure for Scheduling and Reporting Corrective Action The Division Forester is directly responsible for implementing corrective action although they may coordinate this work with other Forestry management personnel within the Division. Corrective work is generally reported through the crew time sheet reports. These time sheets are reviewed by the Forester and filed at the.

Divisional level.

.1. Priority A Conditions Trees, brush, and/or unauthorized use that appear to be threatening the safe, reliable operation of the facility is closely evaluated during the Forester's aerial assessment by either circling the area or landing to make an on-site evaluation. If, in the Forester's judgment, immediate action is required, the appropriate field offices are contacted directly so that crews can be dispatched as soon as, practicable to remedy the condition.

2. Priority B Conditions:

If the evaluation procedure described above indicates that the required work is not

an imminent hazard, but instead requires attention before the next growing season, the Forester notes the situation and schedules corrective action within the appropriate time constraints.

3. Priority C Conditions Priority C conditions generally fall into the routine or pre-planned work scheduling process. The field assessment is used to develop a work plan for off-cycle spot work and danger tree removal or widening in areas that may endanger

-reliability before the line is scheduled again for routine maintenance. Spot work 51

a-includes trees that have been identified as "escapes" or "misses" from past treatments, residential trees that require trimming on a shorter cycle than the rest of the line, and trimming or removing edge trees that have become a hazard since the last review.

These assessments also help to determine the optimal cycle length for each right-of-way within the guidelines of the eight-year cycle. This on-going field information is essential to the decision making process to short-cycle or long-cycle a right-of-way. These field reviews effectively monitor treatment efficacy, reinvasion, growth rates, growing season variations, and program performance.

They also help to determine the effectiveness of previous treatments and schedule adjustments that may have occurred.

C. Determination to Schedule or Delay Maintenance Following the Division Forester's submittal of proposed work-to the Manager of Transmission Forestry, a determination shall be made to either schedule or delay maintenance. This determination is subject to System approval and budgetary constraints, and is principally based on such priorities as safety, reliability, economics, priorities, long-term ROW stability, and herbicide reduction strategies.

1. Safety Safety relates to the requirement to schedule maintenance before the tree conditions create an unsafe work condition or endanger public safety. Vegetation that violates either EOP 211 Priority A clearance requirements, or the OSHA minimum approach distance requirements for safe removal by a qualified line clearance tree trimmer, may require the line to be de-energized before removal can be completed.

2. Reliability Reliability relates to the effectiveness of the vegetation management program in locating and removing tall growing species and preventing tree caused outages. It also includes assuring access for routine and emergency maintenance.

Undesirable vegetation height, danger tree and/or edge encroachment, and the height of buffer zone or residential vegetation may all become reliability factors.

While system reliability is associated with the proximity of the incompatible vegetation to the conductor, treatment effectiveness relates to the height at which the undesirable growth can be most reliably controlled. To ensure system reliability, maintenance must be scheduled to prevent invasion of the wire security uzone. The program maximizes treatment effectiveness by generally targeting undesirable growth when it is at an average height of 10-15 feet.

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Established ROWs consist of a mosaic of shrub and herbaceous communities.

These communities effectively suppress and compete with taller growing tree species, reducing undesirable densities to very light to light conditions. However, optimal cycle timing and the height of treated vegetation have increasingly, become factors in determining how tall the undesirable species are above the desired canopy and how close those stems are to the line. Effective timing requires continued monitoring of the clearances within the wire security zone to insure that the target stems are visible and accessible to the crews, and that they

.have not grown into the wire security zone and compromised reliability. These conditions may require greater, flexibility in treatment heights and schedules going forward.

Conversely, newly cleared ROWs require follow up within one to two growing seasons to effectively control medium to dense regrowth that may not have been effectively controlled with stump treatment at the time of cutting, -The objective is to treat these stump sprouts and root suckers when they average two to five feet in height, minimizing the herbicide requirements to achieve initial conversion.

Treatment effectiveness further relates to the dependability of one'method versus another in achieving long-term control of the target stem. For example, foliar methods are generally more effective in controlling root suckering species than basal or stump treatments. 'Additionally, the treatment of taller Vegetation on longer cycles is possible today through the development and refinement of low-yolume hydraulic foliar applications.

3. Economics Economics relates to the average cost per acre for various management techniques, versus their effectiveness in eradicating undesirable species. Since effective control of taller growing species is paramount to successful right-of-way management, treatments should be scheduled so that the optimum effective control is achieved at the most reasonable cost per acre per year. Additionally, techniques that are not effective in controlling and preventing regrowth or that cause significant damage to or eliminate desirable communities should be minimized.

4. Priorities Priorities relate to the funds available for right-of-way management purposes.

The first priority in recommending a right-of-way for maintenance shall be given to lines where undesirable vegetation is approaching the wire security zone.

The Manager of Transmission Forestry shall review and prioritize local proposals for annual budgeting. A primary objective is to establish level funding requirements and uniform implementation across the System. The historic right-

-of-way acres combined with actual treatment costs for the preceding year shall 53

a-become the basis for budgeting routine maintenance activities in the coming year.

Mid-cycle spot work and danger tree removal efforts are generally budgeted for on an hourly basis. Once annual budgets are approved, the scheduled rights-of-way are assigned for inventory and completion.

5. Long-term right-of-way stability Long-term stability relates to implementation of right-of-way management practices and procedures that result in an ecological condition that maximizes predation and competition; and minimizes reinvasion, treatment costs, and herbicide requirements. It incorporates the latest research and proven best management practices to sustain a fully integrated, ecologically-centered management program.

6. Herbicide reduction strategies Herbicide reduction relates to the strategies and treatment methods available to effectively manage and control undesirable vegetation that escapes the predation and natural competition of the desirable herbaceous and shrub canopy. It relates to developing and implementing herbicide mixtures, treatment methods, and delivery systems that will continue to provide reductions in the amount of herbicide needed to achieve control, while affording the longest possible time between treatments. It also relates to the public, environmental, and aesthetic constraints of the right-of-way. For example, ROWs in highly residential areas may incorporate more non-herbicide methods, thereby requiring shorter treatment cycles. Similarly, ROWs that are constructed along visually sensitive highways may require shorter cycles to provide effective control without creating significant "brown-out" conditions.

D. Procedure for Budgeting and Scheduling of Routine Maintenance The Manager of Transmission Forestry shall maintain a master list of all rights-of-way to show the scheduled year for future maintenance activities and the actual acres completed in past years. The master list will be provided to the Division Forester and reviewed and updated annually to adjust for varying field conditions. It will also incorporate the results of the annual field assessment performed by the Division Forester. A copy of the transmission masters for the fourth management cycle showing the management plan for each ROW during the fourth cycle from 2001-2008 are included in Appendix 6.

The Division Forester shall utilize routine field and helicopter assessments to determine vegetation conditions. A right-of-way shall be scheduled for review the year immediately following treatment to evaluate the treatment's thoroughness and effectiveness. The right-of-way shall be scheduled for a general reassessment near mid-cycle, and then again annually as required to monitor growth near the end of the cycle. The Division Forester shall submit proposed revisions to the Manager of 54

Transmission Forestry each year as required for timely review and incorporation into the budget approval process. The Division Forester shall further identify those lines or activities recommended for mid-cycle spot work, trimming, or danger tree widening for the budget process together with pertinent remarks about priorities,

'short- or long-cycle requirements, sensitive resources, or special treatments. These aninual work-'plan recommendations are prepared on the basis of ongoing familiarity with local conditions, field review, analysis of right-of-way reports, records of previous treatments, and reports for other departments.

The Manager of Transmission Forestry shall then review and prioritize the Division recommendations, and prepare a preliminary work plan for the budget year in accordance with the annual schedule format illustrated below. Treatment costs are estimated based on actual unit costs per acre for routine maintenance within the right-of-way, while mid-cycle spot work and danger tree removal efforts are generally estimated on an hourly basis.

The following chart illustrates the timing of various ROW management scheduling and budget activities from the field assessments to contracting when required.

Time Frame for the Transmission ROW Maintenance Scheduling Process May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr Field Assessments Field Proposals Preliminary Budgets Schedules Finalized Budgets Approved Contracts Bid ;--'. : . -

Permitting..

Once the work plan is approved ihrough the budget process,' the Manager of Transmission Forestry shall develop an annual work plan, for each Region in*'

accordance with the following format. This plan will then be'distributed to the Division Forester for review, comment, and implementation. The process is never static and allows room for modification 'an time field conditions change. This process allows for schedule changes to address changing field conditions and reliability requirements.

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RIGHT-OF-WAY MANAGEMENT PROGRAM Capital Region 2000 Schedule BRUSH ACRES RIGHT-OF-WAY P.R. # KV Brush Acres Scheduled Complete New Scotland - Leeds 912304 345 639.7 639.7 Greenbush - Churchtown 912065 115 234.9 234.9 Castleton Tap 34.5 included 0.0 Brown Co Tap 34.5 included 0.0 Hudson Tap 115 20.0 20.0 Valkin Tap 115 12.1 12.1 Independent Cement Tap 115 24.3 24.3 ADM Milling Tap 115 1.0 1.0 Rosa Rd - Vishers 912130 34.5 5 9.0 9.0 Knoll Sta Tie 34.5 included 0.0 Atomic Sta Tie 34.5 included 0.0 941.0 Danger TreeslSpot Work Rotterdam - Bear Swamp 912306 230 field review Rott to 187 Greenbush - Churchtown 912065 115 widen - 50% complete Kamer - Patroon 912320 34.5 trim, sidetrim & widen North Troy - Tibbetts 912267 34.5 trim, sidetrm & widen School St - North Troy 912101 34.5 trim, sidetrim & widen School St - Maplewood 912226 34.5 trim, sidetrim & widen E. The Transmission Right-of-way Inventory

1. Inventory Method The Division Forester shall ensure a detailed, site-by-site inventory is completed for each electric line right-of-way scheduled for regular maintenance either prior to or at the time of actual treatment. Currently, the Division Forester completes the inventories in advance of actual treatment, but in the future, treatment crews may be able to accurately report equivalent field inventory data at the time of treatment, using advanced information technology and handheld geo-referenced systems. Since gas ROWs are generally maintained by mowing, inventories for these ROWs are not necessary.

2. Purpose of the Site-by-site Inventory A site is an area within the ROW that consists of a common land use pattern or characteristic, or that requires a unique and different treatment method from 56

adjacent areas. Each site may be as large or small as a land use or treatment method requires. The smallest reportable site shall be a tenth of an acre.

The purpose of the inventory is to thoroughly assess site-by-site field conditions, accurately document desirable and undesirable vegetation conditions, insure the assignment of the appropriate prescriptive treatment methods, and record herbicide use requirements. The inventory also identifies special landowner concerns or sensitive site conditions. An example of the'right-of-way inventory is included in Appendix 8.

3. Inventory Records The inventory data is presently collected using handheld data entry systems to record site-specific data. Data collected through the inventory process is then transferred to the master program and summarized for a variety of reports that are used within the maintenance program. >

The items documented in the site-by-site inventory include:

a) Location: The inventory shall describe the site in relation to the adjacent structures, assigning a unique management site number to each site. A management area shall be an area of similar vegetation components that warrant a common management technique.

b) Land use:. The inventory shall identify the right-of-way and/or adjacent land use categories for each site, together with the site sensitivities that influence the management technique that is selected. In the event ,ofmultiple uses or sensitivities, the category having the greatest influence on the maintenance method chosen should be assigned. The special note area can be used to further describe and define sensitivities.

The land use codes have remained unchanged from the beginning of the program, which has allowed for consistent review and performance assessment over the last 23 years. The land use code for a particular site is a combination of numbers assigned to represent the land use activity, height, and density class of undesirables requiring treatment and the density of the retained shrub community.

The land use categories are:

Land use (in the thousands position) 1000 - Streams 2000 - Wetlands 3000 - Road Crossings 4000 - Commercial/Industrial 5000 - Residential 57

Z---

6000 - Active Cropland 7000 - Active Pasture 8000 - Brush Lands 9000 - Woodlands Height - Undesirable, taller growing species (in the hundreds position) 000 - no height 100 - small (less than 6 ft.)

200 - medium (6 to 12 ft.)

300-tall (over 12 ft.)

Density - Undesirables (in the tens position) 00 - no density 10- very light (generally less than 100 stems/acre) 20 - light (up to 30% canopy cover, and 100 to 1,500 stems/acre) 30 - medium (30 - 65% cover, and 1,500 to 5,000 stems/acre) 40 - heavy (greater than 65% cover, and over 5,000 stems/acre)

Density - Compatible shrubs (in the ones position) 0 - none 1 - light (less than 30% woody shrub canopy) 2 - medium (30 - 65% canopy cover) 3 - heavy (greater than 65% canopy closure) c) Plant community: The inventory shall include identifying and reporting the height and density of up to four predominate undesirable taller growing species, together with the density of the predominate desirable woody shrub species. The following species lists shall be used as a guide to identify woody tree and shrub species and their compatibility within each site. Within the limits of any easement, property owner concerns, or environmental constraints, the long-term objective should remain the eventual removal of any species capable of invading the wire security zone, while'retaining and fostering smaller compatible species already present within the site.

Up to four desirable and undesirable species may be reported for each site.

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Undesirable Tall Growing Species The following is a list of tall growing tree species that are considered undesirable in most right-of-way situations and should be removed from the right-of-way floor wherever practicable, to the extent permitted by landowner constraints and easement conditions. The primary objective of the Transmission Right-of-Way Management Program is to effectively remove and control the re-growth and reinvasion of these species.

Ash ASH Cucumber Tree CUC Mountain MAS Elm ELM Balsam Fir BAF Hemlock HEM Basswood BAS Hickory HIC Beech BEE Hophornbeam HOP Birch 'BIR Maple MAP Cherry Oak OAK Black BCH Pine PIN Choke CCH Poplar/Aspen POP Domestic -

DCH Red Mulberry MUL Pin (Fire) . PCH Sassafras SAS Black Gum/Tupelo BGU Spruce SPR Black Locust BLO Tamarack/Larch TAM Black Walnut BWA Tree-of-heaven THE Butternut *BUT Tulip/Yellow Poplar TUL Catalpa CAT Willow WIL

Cedar CED Other OTH Chestnut CHE 59

_ _ _ _ a Small to Medium Trees The following is a list of small to medium trees that may be compatible along the edges of the right-of-way, except on narrower sub-transmission rights-of-ways. They should be removed from under wire areas except where the mature height would not invade the wire security zone, or local conditions do not warrant removal. Any plant on the right-of-way that invades the wire security zone may be removed. These smaller tree species may be preferred for retention in buffer areas and other sensitive sites rather than taller growing tree species.

Species Code Apple APP Buckthom BUC Conrnion Buckthorn European Buckthom

Dogwood Altemate Leaf ADG Flowering FDG Cedars CED American Hombeam

'Ironwood" HOR Hawthorne HAW Mountain Maple MOM Pear PER Shadbush/Serviceberry SHD Shrub Willow WIL Speckded Alder ALD Staghom Surnac SUM Witch Hazel WIH Woody Shrubs The following is a list of shrub species commonly found on rights-of-way across the service territory. While they are nearly always compatible in the border zone, several may grow tall enough to enter the wire security zone.

Any plant that enters the wire security zone may need to be removed.

The conductor to ground clearances, the wire security zone requirements, and the mature height for each species will be key factors in determining which shrubs may be retained in the wire zone at each mid-span. For example, a bulk transmission line, with mid-span conductor-to-ground 60

clearances of 38 feet and a wire security zone of 25 feet can have shrubs with a mature height of up to 13 feet in that site. Shrubs that have invaded the wire security zone will be targeted for removal. As shrub densities in the wire zone exceed 80%, by span, taller growing shrubs may be targeted for removal in an effort to maintain the values and benefits of the herbaceous component.

Species Code American Barberry BAR Chokeberry Black Chokeberry BCB Red Chokeberry RCB Blueberry Low BLU Highbush HBL Button Bush BTN Dewberry DEW Dogwood DOG Red Osier Stiff (similar to Red Osier)

Grey Silky Roundleaf Elderberry ELD Hazelnut HAZ American Hazelnut Beaked Hazelnut Honeysuckle HON Huckleberry Juniper GRJ Dwarf Ground/Trailing Mountain Holly MOH Mountain Laurel MOL New Jersey Tea NJT Norther Prickly Ash NPA Shrub Oak (Bear Oak) SOK Privet PRI Gooseberry RIB Rose Domestic DOR Multiflora MUR Rubus RUB Blackberry Raspberry' Woody Shrubs (continued) 61

- a-Species Code Silverberry American SIL Autumn Olive AUT Sumac SUM Smooth Winged Common Spicebush SPB Spirea SPI Sweetfern Steeple Bush Sweetfem SWF Viburnum VIB Arrowwood ARR Highbush Cranberry HCR Mapleleaf MVB Nannyberry NAN Northern Wild Raisin RAI Hobblebush HOB Winterberry Holly WIN American Yew AMY Climbing Vines Bitterwseet CLB Grape GRA Note that some of these species can be classified as either exotic or invasive -

particularly Autumn and Russian Olive. In addition, some of these species are noxious plants - particularly Multiflora Rose and Poison Sumac. In some situations management objectives within and adjacent to the right-of-way may warrant the removal or reduction of these species. Future discussions with State and Federal agencies to address invasive and exotic species on a landscape scale may require modifications of the current treatment course of action for some species.

d) Other site conditions: The inventory shall also note areas of significant erosion and locations where failure or deterioration of stream crossing devices may have occurred; also dumping, trespass, or other incompatible uses should be noted. The Forester shall note locations where corrective action is required.

Additional landowner contact or notification requirements together with special terms or considerations shall also be noted in the inventory. A separate herbicide notification registry has been developed to identify adjacent landowners that have requested notification before herbicides are applied.

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When the site includes'a State regulated wetland, the DEC regulated wvetland number shall be included in the special notes. Special notes shall also be used to identify locations with unique habitat, including'special endangered species considerations, public and private water resources, etc.

'Plan and profile drawings, together with GIS prints may also be utilized to identify specific site conrcerns. '

e) Site'specific mainienance prescriptions' Finally, site specific maintenance techniques are assigned to eachimanagement area,'after careful consideration' of all external factors. The acreage for each site is calculated.

F. Implementing the Modified "Wire Zoine/Border Zone" Concept

1. Discussion As previously described, the Program has been highly effective at increasing desirable shrub densities and reducing undesirable tree densities'as well as minimizing herbicide use over the past twenty-three years.' However, the increased shrub densities are creatin'g greater accessibility problems for routine and emergency maintenance. In some areas, the intrusion of taller shrubs into the "wire security zone" is also reducing the clearance between the conductor and vegetation beneath the line. While the shrub community may never grow into the line,'it now masks taller growing trees that are dispersed throughout' the shrub layer and competing to' emerge above the shrub canopy. When they finally emerge above the shrubs, they may rapidly grow across the reduced'air'space into the conductors to cause an outage, sometimes within a single'growing season.

"Wire security zone" clearan'ce'requiremnents have been'established to ensure system

reliability. These clearance requirements 'vary by voltage, increasing as voltage increases. They are:

15 feet for sub-transmission (23, 34.5 and 46 kV);

20 feet for transmission (69 and 115.kV);

25 feet' for-bulk transmission' (230 and 345 kV).

The increased clearance requirements of higher voltage line's'are designed to reflect the increased importance of these lines, together 'with'the increased sag experienced on these facilities. ' ' '

While' a primary focus of the Program through the first' three cycles'has' been' increasing shrub densities, research at both thle state and inational level continues to point toward a mosaic of herbaceous and shrub communities'as'providing optimal balance of costs, reliability, and environmental constraints. This, combined with the knowledge that some of these communities have become too tall for the under wire

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- - - MU-area strongly suggests the need for a change in vegetation management philosophies and practices in New York as it relates to the wire zone area. A review of the research in this area may first help to understand the principles and recommended practices needed to assure system reliability.

The role of herbaceous communities in right-of-way vegetation stability and system reliability has been studied extensively by Drs. Bramble and Byrnes during nearly 50 years of research in Pennsylvania. In 1982 they began to discuss a management philosophy they described as the "wire zone/border zone" concept. This approach encouraged the development of shrub communities along the right-of-way edges to resist tree invasion from the adjacent forest, while maintaining the area under the conductor in a blend of grasses, ferns, and herbaceous plants. And so the "wire zone/border zone" terminology was coined to reflect this management approach.

Their work has resulted in adoption of this concept as a best management practice by utilities nationwide, including its adoption into the Pesticide Environmental Stewardship Program, which is a joint effort between the Edison Electric Institute and the U.S. Environmental Protection Agency. National Grid is a participant in the EPA's Pesticide Environmental Stewardship Program.

While the "wire zone/border zone" concept developed by Drs. Bramble and Byrnes encourages shrub communities along the ROW edges, it maintains the under wire area in a mainly herbaceous condition of smaller plants. This maximizes conductor clearances and assures easy access to the facility.

Encouraging dense shrub communities in the border zone, along the edge of the ROW, maximizes the competitive value of these species in resisting tree invasion from the adjacent forest by developing shrubs close to the seed source. The value of the dense shrub edge is affirmed, in the ESSERCO Report EP 91-16, entitled "A 15-year Appraisal of Plant Dynamics," which was a result of research done here in New York. The study identified that seed dispersal is greatest near the forest edge and reduces with distance from the seed source as you move out across the ROW.

Therefore, it has been extrapolated from this study that we can maximize the competitive value by fostering dense shrub communities along the edge.

In New York, the right-of-way management philosophies have encouraged the development of shrubs across the entire ROW, believing that these shrubs would not grow into the conductor and that ROWs dominated by shrub communities would optimize ecological benefits and values. However, National Grid experienced seven outages to the bulk transmission system in New York from 1995 to 1999 where shrub communities hid developing tall growing species from the view of treatment crews.

As these trees emerged above the canopy of the shrub layer following maintenance, they quickly grew into the conductor area to cause an outage. A review of research findings over the last several years also began to indicate greater ecological benefits when a blend, or mosaic of shrub and herbaceous species, are retained within the right-of-way.

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For example, the ESEERCO Report EP 85-38, entitled "ROW Vegetation Dynamics Study," confirmed the important role of mice in seed predation and meadow voles in the'consumption of tree 'seedlings once a seed'germinates. These animals consume thousands of seeds and seedlings'each year that would develop into taller, undesirable vegetation if not for the predator. While,;the white-footed mouse prefers a shrub habitat, a ROW dominated by shrubs could miss the benefit of seed predation that meadow voles provide. The meadow vole frequents the herbaceous community and eats tree seedlings after the seeds germinate. A ROW dominated by herbaceous species would lack the competitive value of the shrub layer and reduce mouse populations that consume seeds before they germinate. The research begins to suggest an ideal ROW mosaic might incorporate-a blend of species conditions, with greater shrub densities along the edges 'and greater retention of herbaceous species toward the middle of the ROW under the conductor.

Another ESSERCO Report, EP 91-16 includes'a'study (No.'3) entitled, "ROW -

Richness and Rarity in' Wetlands Study." This study was among the first to identify the great richness'and'bio-diversity of wetland plant communities that have been created'within the ROW due to past broadcast herbicide applications, including helicopter applications. Several unique, rare and threatened species were found to exist in the ROW due to past broadcast methods. This important richness and -

diversity may be lost in the future if taller shrub 'communities are allowed to'dominate the ROW.'

The State University of New York College of Environmental Science and Forestry has conducted a National Grid research project entitled, "ROW Management of Karner Blue Habitat." Utility ROWs'in eastern New York have been one of the'last remaining areas of significant blue lupine populations. The blue lupine is a critical' habitat for the endangered Karner Blue 'Butterfly. This project investigated the effects of various herbicide treatment methods' on remnant blue lupine populations and'found no long-term adverse impacts on critical lupine habitat from ROW maintenance activities using herbicides. Continuing work indicates that selective herbicide treatments may aid habitat restoiation efforts by effectively controlling unwanted shrub communities, especially scrub oak that have been allowed to expand within the' ROW and outcompete important shade'sensitive lupine and other nectar species.

Most recently, 'observations and field comments by researchers working on the Volney-Marcy 345 kV project in July of 2000 have begun to suggest an optimal shrub component for'songbird nesting' success'may range from 30-70% shrubs. While still unconfirrned, some songbirds nesting in areas of high shrub densities may experience

'increased predation by'small mammals. "At the'same time, herbaceous communities with less than 30%' shrubs may ericourage a shift in songbird nesting success toward grassland or field species. A'mosaic of shrub and herbaceous communities would not only maximize worker access and improve their ability to avoid "skips" and "misses" it could also help maximize habitat and nesting values for the broadest range of songbirds.

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2. Implementation The importance of retaining higher density shrub communities along a forested edge of the ROW is clearly documented and shall remain a key goal of edge or "border zone" management. However, the continuum of research increasingly points to improved reliability and ecological benefits when the Program modifies the national definition of the "wire zone" from just herbaceous communities to include a rich mosaic of small shrubs and herbaceous plants. This expansion of the herbaceous component within the "wire zone" will increase the reliability, economic, and environmental benefits of the Program. At the same time this modification will create unique challenges and require enhanced crew training, coordination, and supervision in order to selectively target some shrub species while retaining others.

These challenges include teaching the crews to determine mid-span conductor-to-ground clearances, to apply the wire security zone standards for a facility, and to determine the mature height of shrubs that can be retained in the wire zone. These conductor-to-ground clearances vary with terrain, tower height and design, ambient temperature and sag variation. Some shrubs may be allowed to remain closer to a tower site while having to be removed near mid-span. In addition, crews will need to learn to identify individual shrub species much the same as they identify various tree species today. This information will need to be combined with the mature height of the species, and measured against the mid-span ground clearance and the wire security zone requirements.

Taller mid-spans may not require intervention to remove shrubs, while other low profile sites may require conversion of the entire mid-span if tall growing shrubs have already invaded the wire security zone and are dominating the wire zone. Most sites will only need selective removal to target individual stems or clumps of shrubs that have already grown into the "wire security zone."

For each line, crews will be instructed in the wire security zone clearances at the time of scheduled maintenance. They will strive to create a blend of herbaceous and shrub species where the maximum shrub component in the "wire zone" is generally no more than 70%. To the extent practicable, access routes, paths, and small openings will be created in the taller or more dense wire zones to enable future crew movement through the shrub layer to control the dispersed and emerging tree species.

Today, only a small percentage of the mid-spans have become overgrown with shrub species. This small percentage of sites enhances our ability to train crews to selectively target problem sites and mid-spans while minimizing costs and herbicide use requirements. At the same time, failure to institute corrective measures at this time will only magnify the problem going forward, increasing the threat to system reliability. Failure to act will also result in greater habitat disruption and destruction when remedial measures are finally implemented.

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Actual implementation of the wire security zone clearance requirements will require a combination of site specific, selective herbicide and manual treatment methods.

Some removal can be incorporated into the routine treatment schedule. Other sites will require off-cycle mowing or clearing to eliminate the initial threat, combined with a follow up herbicide treatment to target smaller resprouts and minimize herbicide use requirements. -

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__________ ________________ ---- U--

G. Definitions and Selection Criteria of Vegetation Management Techniques National Grid currently recognizes eight vegetation management techniques, with variations thereof to prescribe maintenance based on specific site conditions. A descriptive analysis of each vegetation management technique follows, including a list of site parameters associated with the selection criteria for each method. These guidelines are factored into the right-of-way management inventory and treatment prescription process by the Division Forester.

The Company recognizes that site conditions vary widely and a multitude of desirable and undesirable species conditions may occur within any given mile of line. The following guidelines have been instituted to meet this maintenance requirement in a manner that cost effectively controls undesirable species and retains desirable species whenever practicable, and minimizes adverse environmental impacts. The basis of the company's Integrated Vegetation Management (IVM) program is recognition that each technique is suited to certain site conditions and that, given the wide variation in field conditions, no one tool is suitable to all sites.

1. Buffer Zones Inherent in the National Grid's procedures for selection of treatment methods is consideration of buffer zones, which are designated to minimize the potential for off-target damage. When it becomes necessary to treat in proximity to aquatic resources such as streams, lakes, rivers, ponds, or non-jurisdictional wetlands with standing water, minimum buffer zones for use of non-aquatic herbicides shall be:

5 feet for cut/stump treatment

15 feet for low-volume backpack foliar

25 feet for low-volume hydraulic foliar

50 feet for high-volume hydraulic stem foliar Note: Certain herbicide product label restrictions may be greater than these buffer zones. The more restrictive requirements are always followed.

Herbicides shall not be used within 100 feet of a potable water supply or DEC regulated wetland, unless otherwise allowed by permit, rule, or regulation. The Company is developing an Arcview GIS layer within its transmission mapping system that will help identify public water supplies located near our facilities.

Herbicide application within DEC regulated wetlands or the adjacent 100-foot buffer area is done in concert with the Company's statewide freshwaters wetland permit.

This allows the Company to use the low-volume hydraulic foliar, low-volume backpack foliar, or the cut-stump treatment methods within regulated wetlands and adjacent buffer zones to control target vegetation. Herbicides with aquatic labeling are approved for use with these three methods.

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Buffer zones or no treat zones are also-incorporated for sensitive land uses such as active residential, active croplands'and orchards, organic farms, active public parks, schools, and public recreational areas including golf courses and athletic fields.

For all foliar techniques a buffer zone of reasonable size, generally 25-100 feet is maintained around active residential areas'depending on site specifics.

When herbicide treatment is required within these buffer zones for active residences,'cut and stump treatnient methods are used.

For active croplands including active orchards, low-volume hydraulic foliar techniques use buffer zones ranging from 0-50 feet. For high-volume hydraulic foliar applications, the buffer zone range is generally increased to 25-100 feet depending on'site specifics. The range depends on ihe'density of brush to be maintained and the potential for the applicator to position the vehicle in such a way to allow application to be directed away from the crop.

Low-volume backpack' foliar and cut and stump treatment methods may be used right up to the 'edge of active cropland and orchards where'appropriate.

With the backpack method the applicator will stand and direct the' application away from the crop or orchard area.

For active parks, schools, and athletic fields,' the buffers zones for foliar applications range from 10-25 feet for low-volume backpack operations to 10-50 feetffor'low-volume hydraulic,'and'25-100 feet for high-volume hydraulic foliar applications. Note that no work may be completed on the 'prbperty of public or private schools, or registered day care facilities without advance pre-notification under the NYS DEC pesticide notification regulations.

All of the specific buffer zone'applications are included in the individual application method descriptions later in this'section. 'In all cases, National Grid may utilize greater distances when the Forester conducting the field inventory finds aesthetic, public, or environmental reasons to increase the size of a buffer zone. This procedure allows the Forester to consider sit6'specifics like slope, rock outcrops, soil conditions,

' densities of vegetative ground cover, proximity to water, height and density of undesirables, wire security zone,- type and location of cropsrnatural buffers, and any off right-of-way sensitive areas.

2. Environmental Impacts Environmental impacts common to all vegetation management techniques are discussed -below. The environmental impacts associated with a particular maintenance technique are discussed in the appropriate section.

The procedures outlined in this Transmission Right-of-way Management Program are primarily directed towards minimizing and avoiding any potentially adverse environmental impacts associated with herbicide'applications." It has been' proven that those adverse impacts to adjacent land, water resources, and off right-of-way 69

vegetation can be minimized or completely avoided using prescription programming, proper buffer zones, appropriate supervision, and responsible, careful herbicide applications.

3. Off-Site Herbicide Movement A study completed by the engineering firm of Calocerinos and Spina, "Herbicide Mobility Study," analyzed herbicide persistence in soil and movement from overland flow, soil leaching, and drift. The persistence of three herbicides (triclopyr, picloram, and 2, 4-D) used on rights-of-way in upstate New York was found to be no longer than 10 weeks. Since these herbicides biodegrade rapidly, the risk of off-site movement approaches zero, especially when proper buffer zones are established.

According to the "Herbicide Mobility Study" off-site movement of herbicides by overland flow into nearby streams, lakes, ponds, etc. was found to be highly unlikely.

Overland flow of herbicides can occur when herbicide applications are immediately followed by rainfall. However, the linear extent of herbicide movement is minimal, as the herbicide degrades rapidly. Vegetation buffer zones are the key to preventing herbicide movement into environmentally sensitive areas.

Herbicide movement into groundwater via leaching is also highly unlikely. The "Herbicide Mobility Study" found that herbicide leaching to a depth of only 10-15 inches is rare. Downward leaching of herbicides is generally caused by rainfall immediately after application, heavy rainfall within a day after application, or through an application method that deposits large quantities of herbicide directly on the soil, such as conventional basal. For this reason, the company seldom uses basal application. The low-volume backpack foliar method has effectively replaced most basal applications today. The potential for herbicide leaching can be better minimized through the use of foliar techniques, since the majority of the herbicide product is targeted and intercepted by the foliage of the plant and does not reach the soil level.

Additionally, a 1994 Tufts University study entitled, "Study of Environmental Fates of Herbicides in Wetlands on Electric Utility Rights-of-way in Massachusetts over the Short Tenn," investigated the fate of two herbicides, triclopyr and glyphosate when applied in wetlands. That study identified low-volume foliar applications with glyphosate as the method of choice for controlling targeted trees. It also found there was no lateral or vertical movement of glyphosate in the soil, nor was there any accumulation of the herbicide.

Other herbicides used at National Grid, but not included in these studies are fosamine and imazapyr. However, the "Herbicide Handbook, Weed Science Society of America, Seventh Edition-1994" tells us that these products have little to no mobility in soil following application.

Off-site herbicide movement through drift can be avoided through proper application techniques. In fact, herbicides were not found at any off-site locations in this study.

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4. Soils Impacts to soils from vegetation maintenance techniques arise from compaction and rutting caused by maintenance equipment traffic along the right-of-way. An ESEERCO Report 80-5 entitled "Cost Comparison of Right-of-way Treatment Methods," found that soil compaction from wheeled maintenance equipment does occur; however, the amount of compaction is minor. A limited amount of erosion in the wheel tracks occur after treatment then diminishes during the following growing season. Due to the "once through" nature of maintenance equipment, compaction and erosion impacts from vegetation management activities are considered inconsequential.

5. Wildlife An ecologically-centered approach to right-of-way management, employing IVM methods, promotes the selective retention of compatible vegetation and seldom results in long-term adverse effects on wildlife. Instead, selective maintenance techniques generally increase the abundance and diversity of plant species within the right-of-way that are preferred by wildlife for food or cover. In contrast, non-selective treatment methods such as mowing will cause an immediate temporary reduction in cover and reduce or eliminate many food sources for smaller mammals and birds.

The research of Drs. Bramble and Byrnes on Gameland's 33 in Central Pennsylvania was one of the first studies to identify the benefits to wildlife from herbicide use on rights-of-way. In fact, many wildlife species are known to utilize rights-of-way to meet their habitat requirements for nesting, foraging, bedding, and cover.

The 1982 ESEERCO Report EP 82-13, "The Effects of Right-of-way Vegetation Management on Wildlife Habitat," identified that while high-volume broadcast methods had the most immediate effect on reducing food and cover available to wildlife; selective methods helped to minimize these impacts. In addition, a successfully managed ROW develops relatively stable shrub/herb/grass communities that benefit a wide variety of species. Furthermore, while the ROW cannot meet the habitat needs of all species, vegetation management on ROWs encourages a broad spectrum of species.

More recent research conducted by the State University of New York at the College of Environmental Science and Forestry in 2000 and 2001, "Effects on Vegetation Management on the Avian Community of a Power Line Right-of-way," investigated the site specific effects of vegetation management on songbird communities. This study found that shrub-nesting songbirds respond directly to shrub habitat on ROWs.

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Songbird nesting increased as shrub density increased. Field observations by researchers suggested there might be an upper limit to this increased nesting as shrub density increases beyond 70%. The study found that once established, the permanence of the plant community that is produced through selective herbicide application may be better for relatively short-lived bird species than the regular destruction of those communities through normal mechanical maintenance methods such as mowing.

r S

- rc -. S Cedar Waxwing sitting on her nest on National Grid's Volney-MarcyROW..

6. Density Definitions:

The brush density definitions used by National Grid to identify the density of either desirable or undesirable woody plant species are: -

S Very Light (undesirable only, generally less than 100 stems/acre)

S Light up to 30% canopy cover S Medium 30 to 65% canopy cover S Heavy greater than 65% canopy cover

- ' 'a- en - I ' ! "

Another guideline for assessing undesirable densities translates these percents of cover into approximate stem densities as follows:. .f I I. . 1

Very Light 100 stems/acre or less

. Light 100 to 1,500 stems/acre 72

Medium 1,500 to 5,000 stems/acre

Dense greater than 5,000 stems/acre

7. Height Definitions:

The height definitions used by National Grid to identify the height of vegetation to be treated are as follows:

Small less than 6 feet Medium 6-12 feet

Tall over 12 feet The average heights of vegetation to be treated are captured in the site inventory data.

Within a site there may be a wide range of vegetation heights. Generally, for sites where the average vegetation height is over 15-16 feet, a foliar herbicide treatment is not appropriate. On these sites an initial cut and stump treatment, possibly followed by a low-volume backpack operation, may produce more effective control while minimizing the risk of off-target treatment and the total amount of herbicide per acre necessary to achieve total control. While there are situations where the average height of target vegetation on a foliar site may be only 8-10 feet, there may be scattered stems on the same site that are as tall as 18-20 feet. It is allowable and appropriate for the crew to foliar treat these taller stems as long as they are away from sensitive environmental resources and areas of high visual sensitivity, and the crew is able to get into close proximity of the target to prevent off right-of-way drift. In these situations the applicator should be riding on the rig 4-6 feet off the ground, and extending their arms and spray guns to effectively reduce the application distance from 20-feet back down to 10-12 feet. This will increase the accuracy and efficiency of the herbicide application onto the target foliage and minimize the potential for off-target damage.

8. Vegetation Management Techniques The approved vegetation management applications include:

a. High-Volume Hydraulic Stem-foliar

b. Low-Volume Hydraulic Foliar

c. Low-Volume Backpack Foliar

d. Cut and Stump Treatment

e. Basal Application

f. Cutting and Trimming, No Herbicide Treatment

g. Mowing

h. Mowing and Cut Stubble Herbicide Treatment

i. Helicopter 73

Each method will be discussed in detail in the following pages of this section.

. ; . . !. I

a. High-Volume -Hydraulic Stem-Foliar Application Application: Target-Selective stem foliar requires full 'coverage of the target plant's leaves, branches, and stem to the point of runioff. This mneth6d is especially effective'for controlling; medium- to high-density undesirable vegetation, while minimizing herbicide use requirements as much as possible.

Equipment: All-terrain type vehicle, hydraulic tank, pump, hoses and spray guns.

Herbicide:' Selective or non-selective'pro'ducts available, approximately 60-120 mixture gallons/acre depending on target species density.

Limitations: In dense brush conditions, walking or hose dragging becomes 'onerous; therefore, applications from the spray-unit are the most efficient and 'effective method for treating'dense or tall stands of undesirable species. Selectivity increases as density decreases an'd spacing between target and non-target vegetation in cre'ases. It is most effective' on sites where the average heights are less than 15-16 feet.'

Drift: Operatingpressurebelow 150 psi at the nozzle and operator is less than 10 feet from the targetplant. Mix additives such as surfactants and drift control agents are utilized.

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Buffer zones: The use of high-volume hydraulic foliar shall be avoided within:

50 feet of streams, ponds, unregulated wetlands, or lakes with standing water and/or running water

100 feet of a regulated wetland, unless otherwise allowed by permit (Note that this technique may only be used inside this buffer when treating undesirable stems in seasonally dry wetlands or adjacent area using products approved for aquatic applications in accordance with approved wetland permits. Low-volume hydraulic methods shall be preferred to high-volume methods where ever possible.)

100 feet of an active residence or ornamental plantings

100 feet of active croplands, orchards, etc.

100 feet of active parks, schools, athletic fields, golf courses, etc.

Visual Effects: Some brownout may be caused by dead or dying foliage, which may be mitigated by selective application. The remaining green, compatible vegetation also reduces this effect.

Full discussion of Technique:

The high-volume stem foliar technique is especially effective for sites with high undesirable densities. The higher spray pressures help ensure adequate plant coverage on these sites, while the reduced herbicide concentration in the mixture helps minimize the amount of active ingredient applied per acre. As undesirable densities rarely reach these conditions today, this application method is not required as often as it was in earlier cycles.

Application: A herbicide mix is directed at the target vegetation so as to wet all leaves, branches, and stems to the point of runoff. The applicator should be within 10 feet of the target plant in order to maximize application efficiency and effectiveness and minimize off target damage. To further minimize drift, the operating pressure of the unit should not exceed 150 psi at the nozzle, and the nozzle opening shall be regulated so as to produce a coarse spray of large droplets.

Equipment: The application equipment generally includes an all-terrain type vehicle, either tracked or rubber tired, and mounted with a hydraulically operated pump, a 100-1000 gallon mix tank, two hoses at least 100 feet long, and two spray guns with suitable nozzles. Ground support equipment includes a 500-1000 gallon water resupply truck. Manpower normally consists of 3-4 persons.

Herbicide: The herbicide mix contains generally less than 1% active ingredient and is applied at an average of 60-120 intture gallons per acre, depending upon undesirable species density.

Application rates may run as high as 300-400 gallons per acre on high-density sites. While selective herbicide mixtures are preferred for high-volume applications, because they tend to preserve more grass and fern species in the site. Non-selective mixtures may be used when the herbicides provide environmental advantages such as aquatic labeling, reduced soil residual, or less active ingredient per acre.

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Limitations: When dense brush conditions make walking or hose dragging onerous, or the scattered spacing of desirable or undesirable stems would improve crew efficiency, the crew is authorized to make the treatment while riding on the back of the spray unit. Application from the elevated platform also helps improve selectivity by keeping the applicator closer to the canopy of the undesirable vegetation, often enabling them to treat down onto the target stems.

This treatment should not be used on sites where average brush heights exceed 15-16 feet.

' Individual trees or small clones of taller vegetation up to about 20 feet may be treated when the applicator can get in close proximity to -thetarget with the vehicle and spray from-the elevated deck to reduce the potential for over spray and off-target damage.

Environmental Considerations: '

-Drift: High-volume hydraulic applications have the greatest risk of drift due to the high operating pressures and increased application rates. Mix additives, including surfactants and' drift control agents, are required to eliminate small droplets and prevent drift. In addition, limits on the height of target'vegetation, treatment distance, and the size of the nozzle opening helps minimize the potential for off-target damage.

This method has the greatest "zone of effect"on adjacent understo'y vegetation of all the

-approved foliar methods, due to the higher pressures and application rates. However, this increased pressure is necessary to achieve effective control in medium to dense stands and has been one of the foremost reasons for the past success of the program. The broader zone of effect is also helpful for economically converting tall or dense woody stands to the more compatible herbaceous stands in the wire zone, while using less herbicide than either low-volume foliar or cut and stump treatment in these higher densities.

Buffer zones: -Where site conditions warrant larger buffers, the Forester shall so designate as part of the site-by-site assessment and/or ground follow up.

Visual Effects: The short-term visual effect from the high volume hydraulic stem-foliar technique is the variable brownout condition caused by dead or dying foliage. The green, non-target, and compatible vegetation remaining on the treatment site mitigate the overall brownout effect. A long-term visual impact associated with this fechnique imay be the sight of dead stems following the treatment. -

Site Conditions Favorable for this Technique:

High-volume hydraulic stem-foliar application may be specified when the treated portion of the right-of-way:

1. has dense undesirable species (65-100%); or

2. has moderate (30 65%) to dense (651100%) undesirable species, with light to medium' desirable species (1-65%); or

3. is within the mid-span, wire zone site that contains tall or dense shrubs. High-volume treatment with more diluted mixtures would provide proper coverage and reduce herbicide use, while converting the site to a stable mix of grass and herbaceous species;-and .

4. site proposed for treatment is accessible to ground equipment; and the site is sufficiently removed from environmentally sensitive sites so as to minimize'potential impacts unless 76

otherwise allowed by permit.

b. Low-Volume Hydraulic Foliar Application Application: Target-Selective Foliar requires coverage to lightly wet the leaves, all growing tip areas, and the entire terminal leader area of the target plant.

Equipment: All-terrain type vehicle, hydraulic tank, pump, hoses, and spray guns.

Herbicide: Selective or non-selective products available at rates of approximately 10-40 mixture gallons/acre depending on target species density.

Limitations: In dense brush conditions, undesirable densities may be too high to insure adequate coverage, and walking or hose dragging may become onerous. Selectivity is dependent on density and spacing of target/non-target vegetation. Use on lower density sites with average heights of less than 15-16 feet.

Drift: Operatingpressure below 50-pounds/squareinch (psi) at the nozzle with the operator within 10 feet of the targetplant. Mix additives such as surfactants and drift control agents are necessary.

Buffer zones: The use of low-volume hydraulic foliar shall be avoided within:

25 feet of streams, ponds, unregulated wetlands, or lakes with standing and/or flowing water

100 feet of a regulated wetland, unless otherwise allowed by special wetlands permit 77.

(Note that this technique may only be used inside this buffer when treating undesirable stems in seasonally dry wetlands or adjacent area using products approved for aquatic applications in accordance with'approved wetland permits.)

25-1 00 feet of an active residence or ornamental plantings

' 0-50 feet of active croplands, orchards, etc.'

10-50 feet of active parks, schools, athletic fields, golf courses, etc.

Visual Effects: Some brownout may be caused by dead or dying foliage, howeverjit may be mitigated by increased selectivity. The remaining green, compatible vegetation on the treatment site will also mitigate this effect.

Full discussion of technique:

Low-volume hydraulic foliar is currently the predominate treatment prescribed by the Company for all non-sensitive, upland sites. This method was used to treat 100% of the brush acres receiving hydraulic foliar application in 2001, which completely replaced the high-volume' technique. This conversion to highly selective, low-volume methods across nearly all of the ROW system was possible due to-the effectiveness 'ofpast methods and reductions in :

undesirable densities 'over the past two decades.

Application: A herbicide mix is directed at the target vegetation so as to lightly wet the leaves in all growiing tip areas and across the entire terminal leader area of the targetplant.'The applicator should'be 'within 10 feet of the target plant in order to maximize the accuracy of the application and minimize off-target damage. To further minimize drift, the Ioperating' pressure of the unit should not exceed 50 psi at the nozzle, and the nozzle opening shall be regulated so as to produce a coarse spray of large droplets.

Equipment: The application equipment'generally includes an all-terrain'type vehicle, either tracked or rubber'tired that is mounted with a hydraulically operated pumiip, a 100-1 000 gillon mix tank, two hoses at least 100-feet long, and two spray guns 'withsuitable nozzles. Ground support equipment includes a 500-1000 gallon water resupply truck. Manpower normally consists of 3-4 persons.

One highly'specialiized variation 'of this method includes low-volume foliar applied 'through a Radiarc nozzle mounted on four-wheel ATVs for access roads, designated wire zone areas, and narrow ROWs, such-as gas' rights-'of-way. This method limits thi application width to -

approximately 20 feet. The method uses a smallpump and 15-30 gallon tank.'

Herbicide: The herbicide mix contains generally 1-2% active ingredienit and is applied at an averageof 1040 mixture gallons per acre depending upon undesirable species density. Either a selective or non-selective herbicide can be used. A selective herbicid6 will tend to preserve more ground cover'v'egetation such as grasses, herbs, and ferns on floor, 0theright-of-way which maybe preferential; However, some non-selective herbicide products may have a lower environmental risk or m'aiy require less active ingredient per acre.

Limitations: Since much of the Company's rights-of-way now contain medium to dense 78

populations of compatible vegetation, walking or hose dragging has become difficult.- For that reason, crews generally make this foliar application from the deck of the vehicle. By working from this elevated position, targeting the undesirable stems is improved by enabling the applicator to work from above the target. The lower pressures require the applicator be within approximately 10 feet of the target stem. However, the crew must not increase nozzle pressures to extend their reach or herbicide use will increase. This technique should not be used to control high-density sites, because the lower pressures and lighter wetting will result in poor coverage of dense vegetation. Increasing the pressure will rapidly increase the gallons/acre requirements.

Low-volume hydraulic foliar should not be used on sites where average undesirable brush heights are above 15-16 feet. Individual trees or small clones of taller vegetation up to about 20 feet may be treated when the applicator can get in close proximity to the target with the vehicle and spray from the deck to reduce the potential for over spray and off-target damage.

Environmental Considerations:

Drift: Effectively controlled and prevented with low-volume hydraulic applications through reduced pressures and control of nozzle openings to create large, course droplets. Mix additives such as surfactants are required to improve surface wetting and adherence of the herbicide on the leaf together with thickening or drift control agents that help to eliminate the formation of small droplets or "fines" and prevent drift. Drift and off-target damage can be minimized by limiting the applicator's distance from the target stem by reducing the height of the target vegetation and by decreasing spray pressures.

The phrase "zone of effect" has been coined to describe the "shadow effect" of the spray pattern on adjacent understory vegetation. Whenever herbicides are foliar applied to wet the leaf surface of the target plant, some mixture falls on adjacent understory vegetation within the right-of-way. As long as the spray pattern is contained within the right-of-way, this zone of effect of the spray pattern is not considered a drift problem.

Different application methods will have different "zones of effect." The size or extent of the impact on adjacent understory vegetation increases as operating pressures, treatment rates, and the distance increases from the nozzle to the target vegetation. The Program has always weighed and balanced the loss of compatible vegetation against the requirements for effective control and long-term reliability. As treatments have become more selective over the years, the "zone of effect" has become much smaller. When compared to past helicopter or high-volume foliar applications for dense brush, today's low-volume foliar methods have a vastly reduced "zone of effect" within the total right-of-way.

Recent studies on the Volney-Marcy ROW have begun to investigate this effect for a variety of treatments. Preliminary results indicate that most of the spray pattern that falls on adjacent, understory vegetation is intercepted by the foliage of those plants with very little herbicide actually reaching the soil. In addition, the effect on the herbaceous communities varies with different herbicide mixtures. Most sites experience a temporary setback but begin to recover within the same growing season and are fully revegetated by the next growing season.

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Buffer zones: Where site conditions warrant larger buffers, the Forester shall so designate as part of the site-by-site assessment and/or ground follow up.

Visual Effects: The short-term visual effect from the highly selective low-volume foliar technique is the variable brownout condition caused by dead or dying foliage. High selectivity and the green, non-target compatible vegetation remaining on the treatment site mitigate the overall brownout effect. A long-term visual impact associated with this technique can be the sight of dead stems that remain in the treatment site for a few years following treatment.

Site Conditions Favorable for this Technique: Selective low-volume hydraulic foliar applications maybe specified when the right-of-way is:

1. a wide right-of-way (150+ feet) where backpack foliar operations become inefficient; or

2. a right-of-way with medium to dense desirables that are too tall for back pack operations, and very light to light tall growing stems where riding the unit would place the applicator on an elevated platform above the desirable shrub layer, improving treatment effectiveness, or

3. a right-of-way with medium to heavy undesirable species densities and average heights of 15-16 feet or less, where the high-volume stem foliar treatment is neither appropriate, practical, or necessary; and

4. the site proposed for treatment is accessible to ground equipment; and

5. the site is sufficiently removed from environmentally sensitive sites so as to minimize potential impacts unless otherwise allowed by permit.

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c. Low-Volume Backpack Foliar Application-Application: Target-Selective Foliar requires very light wetting 'ofthe leaves, especially in'the growing tip and terminal leader areas of the target plant.

Equipment: Hand powered or motorized backpack tank and spray gun with a two-way nozzle to apply either a cone or stream pattern-Herbicide: Selective or non-selective' products available in a variety of different tank mixes and modes of action. Mix generally at 4-6% active ingredient, apply at apjroxirnately 3-6 gals per acre.

Limitations: Selectivity is dependent on density and spacing of target and non-target vegetation.

Use on sites with average heights of less thanl 10-12 feet and verylight to light target densities.

Drift: Relatively low press'ure application at close target distances. Surfactants are required and drift control agents may be utilized.

Buffer Zones: The use of low-volurne backpack methods shall be avoided within'

15 feet of streams, ponds, unregulated wetlands, or lakes with standing and/or flowing water ,

100 feet of a regulated wetland, unless' therwise allowed by permit 82

(Note that this technique may be used as a preferred treatment method within wetland buffers when treating undesirable stems with approved aquatic products in seasonally dry wetlands or adjacent areas, in accordance with approved wetland permits.)

25-100 feet of an active residence or ornamental plantings

10-25 feet of active parks, schools, athletic fields, golf courses, etc.

No buffer is required for this technique next to crop fields or orchards when the treatment can be directed away from the crop area.

Visual Effects: Some scattered, variable brownout caused by dead or dying foliage may be mitigated by high selectivity and the effect of the green, non-target, compatible vegetation remaining on the treatment site.

Full discussion of Technique:

The l6w-volume backpack method is especially effective on narrower ROWs in very light to light density sites where desirable densities are low enough to allow the applicator to traverse the site by foot. This treatment is also preferred for the treatment of sensitive buffer areas as research has shown that less herbicide is deposited on the soil surface as compared to cut and stump treatment.

Application: The herbicide mix is directed at the target vegetation so as to very lightly wet the leaves in the growing tip and terminal leader areas of the target plant using a very low pressure application method. The applicator should be within a few feet of the target plant, but not more than 10 feet, in order to'maximize application and minimize off-target damage. To further minimize drift, the operating pressure of the backpack unit should be maintained around 25-30 psi and should never exceed 50 psi at the nozzle. The nozzle opening should be regulated so as

toproduce a coarse spray of large droplets. The spray gun may be equipped with a two-way' nozzle to provide a "cone" pattern for the treatment of smaller vegetation as well as a "stream" pattern for the treatment of taller target plants.

Equipment: Manpower niormally consists of two or more persons. The most common backpack system consists of a hand operated simple diaphragm or piston-pump backpack equipped with a spray wand and one nozzle (either a flat fan or.adjustable cone). As an added feature many applicators utilize a dual nozzle spray gun that allows the operator to switch between a narrow-angle "stream" nozzle for longer'distances or a ivide-angle "cone" tip for shorter distances and wider coverage.

Herbicide: The herbicide mix contains generally 4-6% active ingredient and is applied at an' average of 3-6 mixture gallons per acre depending upon undesirable species density. Either a selective or non-selective herbicide can be used. A selective herbicide will tend to preserve more iroundcover vegetation such as grasses, herbs, and ferns on the right-of-way floor, which may be preferential. However, some non-selective herbicide products may have a lower environmental risk or may require less active ingredient per acre.

Limitations: This treatment should not be used on sites where average heights exceed 10-12 feet. Occasionally, individual stems or clones of stems upwards of 15 feet can be treated using 83

the "stream" pattern nozzle as long as the applicator can get into a good position for treatment and minimize off-target damage. Low-volume backpack should not be used to treat continuous areas of moderate to dense undesirables since the application rates as measured by active ingredient may be too high for the higher density sites. The low-volume or high-volume hydraulic methods would reduce the application rates for those situations.

Environmental Considerations:

Drift: The close proximity of the applicator to the target, 'along with the low pressure of the backpack equipment makes the risk of drift virtually non-existent. Mix additives such as surfactants are required for uniform spreading of the herbicide mix over the leaf surface, and drift control agents may be necessary when using motorized backpacks.

The reduced pressures and close proximity of the application make the "zone'of effect" for this treatment smaller than what is experienced with the hydraulic foliar methods.

-Buffer zones: Where site conditions warrant larger buffers, the Forester shall so designate as part of the site-by-site assessment and/or ground follow up.

Visual Effects: The short-term visual effect from'the low-volume backpack foliar technique is the variable brownout condition caused by dead or dying foliage. High selectivity and the green, non-target, compatible vegetation remaining on the treatment site mitigate the overall brownout effect. A long-term visual impact associated with this technique may be the presence of dead stems that remain in the treatment site for a few years following treatment.

Site Conditions Favorable for this Technique: X .

The selective low-volume backpack foliar application may be specified when the treated portion of the right-of-way:

a. consists of very light to light undesirable species (0-30%) with average heights below 10-12 feet and light to medium desirable densities that can be traversed by foot; or

b. consists of any density of undesirable species where the only access to the site is by foot; and

c. is sufficiently removed from environmentally sensitive sites so as to minimize potential impacts unless otherwise allowed by permit.

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a-

d. Cut and Stump * .

Treatment I 1 Application: Target-Selective ,Cutting is when the stem is cut and the stump is treated with herbicide to prevent resprouting.

Equipment: Chainsaw and small squirt bottle or backpack tank.

Herbicide: Water-base or oil-base products.

Limitations: Most effective when applied immediately after cutting and during the active growing season.

Drift: Drift is not a significant problem due to low pressures and low-volume applications.

Buffer Zones: The use of non-aquatic products shall be avoided within:

5 feet of a stream, pond, regulated wetland, or lake with standing and/or flowing water.

100 feet of a regulated wetland unless otherwise allowed by permit.

(Note that herbicides that have been registered for use in aquatic settings may be used in wetlands and adjacent areas, by permit, with no direct spray into standing water.)

Visual Effects: The cut slash is the primary visual effect. Various slash disposal methods may be prescribed by the Forester to minimize the impacts on adjoining land uses.

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Full discussion of Technique:

Cut and stump treatment is the preferred method to control undesirable stems within the buffer zones for foliar applications next to residential, active cropland, orchards, public parks, schools, athletic fields, golf courses, etc. It also is the'most common method used to 'control tall growing vegetation'near standing water, when using' approved aquatic herbicides... It may'also be used to clear taller vegetation that has become too tall for the foliar techiniques. 'Finally, this method may be prescribed by the forester for sites that have high visual sensitivity.

Application/Equipment: Cut and stump ,treatments are designed to remove individual stems and chemically control the root' system. The 'technique'is ro6st widely employed inside buffer zones

'for foliar treatment, for cutting of vegetation that is over the foliar height restrictions, or in

'visually sensitive areas. The cutting is primarily accomplished using either a chainsaw or brush saw. Variations in'the manner of slash disposal recognized by National Grid include:' '

Cut and stump treatment is where the slash remains lopped where it falls'.'

' Cut and stump treatment and windro'w is when the' slash is disposed of by hand piling or windrowing.

Cut and stump treatment and chip ari ewhere the slash is disposed of by chipping. The chips may be disposed of on site or hauled away.

Note that in all 'cases, slash may not be left in an identifiable watercourse.

Herbicides: There are two approaches to herbicide materials and applications. One method uses water-borne products'that are applied directly to the cut surface immediately following cutting, while the other uses oil-based products that mray be applied to 'the'entire stump surface any time following clearing, including days'or weeks later.'

1). Water-based herbicide application is accomplished through use of hand-held squirt bottles or small capacity hand or backpack pressure sprayers. The material is either pre-mixed from the manufacturer or field mixed by diluting the concentrate by 50% with water, and applying it to the outer circimference of the cut surface with emphasis on the cambium layer. The application'imust be made immediately after cuttinig. The mode'of entry is through direct uptake into the water-based system of the tree and transported by the phloem tissues down into the roots.:'Delaying treatment after'cutting m ay'allow formation of air bubbles or drying at the cut surface, blocking the trees transport system and preventing'effective translocation bf the herbicide int6 the roots.

2). Oil-based herbicide application uses a backpack hand sprayer to-deliver the oil-based herbicide mixture onto the bark surface of the stump and all exposed roots: The mixture is applied to the point of run down and puddling at the root collar. Followinig application, the herbicide penetrates the bark to disrupt the cambium and prevent emergence of dormant buds within the exposed bark and root collar zone. Translocation of oil-based mixtures into the root system is poorer than other methods, because these oil-based products will not dissolve as easily and enter the water-based transport systems of the tree.

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Limitations: Experience has shown that stump treatment methods often produce unreliable results when used on stumps of root suckering species. Seasonal differences in the plant physiology and herbicide transport mechanisms, as well as human error, also cause variations in results of this technique. Special slash disposal methods like windrowing or chipping escalate per acre maintenance costs beyond the basic cut and stump treatment method where the slash remains lopped where it falls.

Environmental Considerations:

Drift: The high selectivity of this technique causes little or no damage to non-target shrub species. Drift is non-existent due to the low-pressure, close-hand application equipment. Non-target herbaceous vegetation within 6 inches-2 feet from the treated stump may be damaged by herbicide that splashes from the stump during application and from the over spray of the spray pattern falling on adjacent grasses, herbaceous material, and shrub stems. Off-target herbicide movement via root uptake can also occur when using water-based treatments on some species during cut and stump treatment applications. Herbicide applied to the cut stumps can be transported through interconnected root systems and damage or kill trees beyond the edge of the right-of-way. Root suckering tree species that grow in clones are especially susceptible to damage from root uptake.

Buffer Zones: Where site conditions are so sensitive that cut and stump treatment cannot be completed, the Forester may elect to only cut or trim and not use herbicides.

Visual Effects: The short-term visual impacts associated with this technique may be the sharply defined cut edge of the right-of-way, or the sight of drop and lopped or piled brush. The remaining non-target vegetation within the treatment site often mitigates these visual effects.

Site Conditions Favorable for this Technique: Cut and stump treatment should be specified when the proposed site for treatment is:

1. inside the buffer zone area for any of the foliar techniques; or

2. an area of high visual sensitivity, such as heavily-used highways or public park areas, where the undesirable growth requires removal; or

3. an area immedi'ately adjacent to residential areas where, due to intense land use practices, stem removal is warranted over appropriate foliar applications; or

4. an area within the' limits of a public water supply or immediately adjacent to a domestic water supply, where an aquatic herbicide can be approved and prescribed for that use; or

5. within the buffer zone and adjacent area of a regulated wetland and aquatic herbicides are approved for use on the permit; or

6. where individual target plant heights exceed acceptable limits for foliar applications and must be removed.

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e. Basal Applications Am Application: Target-Specific Basal is a spray application applied to the lower'portion of individual standing woody stems. The application requires a thorough'wetting of the lower 12-15 inches of the stem down to ground line including the root collar zone.

Equipment: Most commonly applied with a, -5 gallon, hand-held or backpack unit equipped with a hand pump and spray wand. Various mixtures may also be applied with small, hand-held squirt bottles or even larger hydraulic units, dragging hoses, and using low pressures. Manpower normally consists of a 2-3 person ground crew.

Herbicide: Today, mainly ready-to-use products that contain specially developed penetrants are used, rather than the old, conventional fuel-oil basal mixtures. Various herbicides are diluted in these penetrants at rates of 10-50%.

Limitations: Most effective when used in very small areas during active growing season.

Increased skips and misses as site density and size increase, and when snow covers the base of the stem. Oil-based products have reduced translocation, with poorer control of root suckering species.

:.. ; w . . i . .. '-': . . . . . .

Drift: Drift is not a factor because of the relatively low pressure application and close target distances.

Buffer Zones: The use of basal applications shall be avoided within:

'- 15 feet of a stream, pond, regulated wetland, or lake with standing or flowing water:.

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K_

100 feet of a regulated wetland, unless otherwise allowed by permit Note: Use of basal applications is allowed up to the edge of residential areas, active croplands, orchards, public parks, schools, athletic fields, golf courses, etc.

Visual Effects: Brownout will occur when basal applications are made in either the active growing season or the dormant season. The brownout associated with dormant season treatments actually occurs the following summer. The visual impact is softened by the high selectivity of this treatment that retains a high percentage of the compatible shrub species on the site.

Full discussion of Technique:

The basal method has evolved over the past two decades, specifically in regards to the herbicide products used for this treatment. The old, conventional basal method employed a herbicide diluted in a fuel oil carrier, generally at a rate of 1-4 gallons of herbicide per 100 gallons of mixture (a 1-4% solution). The application was targeted at the lower 12-18 inches ofthe stem, saturating the basal area to the point of rundown and puddling at the root collar zone. There were several disadvantages to the conventional basal application method including:

The method utilized large quantities of fuel oil, requiring as much as 150 gallons per acre or more, adding greatly to the cost, difficulty of handling, and environmental concerns with the application..

Higher herbicide concentrations were generally required to achieve even minimal effectiveness.

Poor agitation and mixing frequency also lead to spotty results.

The low solubility of the oil-borne solution within the plant's water system reduced translocation and led to poor root control of root sprouting species.

Additionally, this limited mobility required more exact application to insure complete coverage and rundown. If the back or side of the stem was missed and not completely encircled, "green streaking" occurred whereby food and nutrients were still able to continue through the thin untreated strip keeping the stem alive. If the stem was circled, but not puddled at the root collar, dormant buds below the treated area would sprout to maintain life within the plant system.

Application when the bark is wet may result in herbicide/oil mixture run-off of the plant, and ultimately poor or no control.

More common and appropriate today is the use of the concentrate basal application method involving the use of specially developed penetrants to replace the fuel oil of conventional basal mixtures. These penetrants are designed to more effectively penetrate the waxy suberin of the bark, carrying the herbicide into the cambium area. These product advancements have helped minimize the effects of many of the issues stated above. The basal method still requires some of the highest rates per acre of herbicide concentrate to achieve effective control. As a result, basal is used only sparingly in the program.

Application: Basal-bark treatments can be effectively used to control brush and trees up to six inches in diameter. Application is made as a fine mist that is used to lightly wet the bark, rather 89

than wetting to the point ofrundown. The-method is useful for selectively removing very light to light density undesirable vegetation where the applicator can traverse the site by foot, and where the right-of-way is not over-grown with shrub species. The number of skips or misses related to this operation increases as shrub density increases due to the difficulty in locating the target stems within a moderate to dense shrub iinderstory. Conventional basal treatments primarily control woody brush'by chemically girdling the stem. ;Treatments can be made any time of the year including the dormant season as long as snow depths do not prevent access to the lower portion of the stem. However, best results occur during growing season treatments' between April and October. With sone he'rbicide products, trees treated in the dormant season may leaf out in the spring since the buds are set, and then wilt and die once stored food reserves are burned up. This browndut'can be a problemin visually sensitive areas.

Equipment:' Equipmenet used for this application c'an vary from small, hand-held squirt bottles to 1-5 gallon, hand-held or backpack units equipped wvith a hand pump and spray wand.

Although uncommon today, it can also be applied using the hydraulic type spray unit normally associated With ground foliar'treatments'. The treatment is directed at the lower'12415 inch portion of the stem and is made with very low pressures using a solid cone or flat fan riozzle.

Manpower normally consists of a 2-3 person ground crew.

Herbicide: Various herbicide ingredients can be formulated by combining them with basal bark penetrants at rates of 10-50% to create a concentrated basal ready-to-use formulation. As this is a low-volume approach, one gallon of concentrate basal solution replaces the equivalent of 10-12 gallons of the old conventional basal mixture. The newer concentrate basal products also provide a systemic mode of action that significantly improves effectiveness by controlling the plant's root system. The combination of the penetrants with a higher herbicide concentration result in more rapid and consistent basal treatments. The higher herbicide concentrations may also tend to avoid the problems of mixing oil-borne and water-borne solutions.

Limitations: The treatment is recommended for stems under six inches in diamieter, on sites with low densities of undesirable brush. The exact, tedious coverage requirements of this application often result in complete misses or only partial control of the target stems. Once within the plants, the degree of mobility and translocation is limited by the poor mixing of oil-based products with the water transport system of the tree. Time of year, tree species, herbicide, carrier, mixture rate, solubility, and other factors all effect control and performance. Basal applications cannot be made when snow prevents the spraying of the stem down to the ground line.

Environmental Considerations:

Drift: The high selectivity of this technique causes little or no damage to' non-target vegetation.

The basal technique utilizes low pressures, because the mixture must be delivered within approximately two feet of the stem. As a result, drift is not a factor.

The "zone of effect" for this application is greater than the zone associated with cut and stump treatment, due to the heavier application rates, fine spray pattern, and the high concentration of the material. Since this application is directed at the base of the target stem and uses the highest 90

application rates of all methods, it places the greatest amount of herbicide at the ground level.

This may result in a high level of herbicide actually reaching the soil and may increase the depth of herbicide leaching. Low-volume backpack foliar methods have generally replaced basal methods in the field, because they require greatly reduced application rates and most'of the over spray or shadow of the spray kattem is intercepted by the foliage of the herbaceous understory and never reaches the ground.

Buffer Zones: Where site conditions warrant larger buffer zones, the Forester shall so designate them as part of the site-by-site assessment and/or ground follow up.

Visual Effects: The short-term visual effect from the basal technique is brownout caused by dead or dying foliage. The overall brownout effect is somewhat mitigated by the high selectivity and retaining compatible shrub and herbaceous vegetation within the site. A longer-term visual effect may be the standing dead stems.

Site Conditions Fav6rable for this Technique: Selective basal applications should be specified when the site proposed for treatment is:

1. A relatively small area, such' as a hedgerow, road crossing, or similar buffer zone, where undesirable densities are very light to light and desirable densities are low, and the crew can easily move through the understory to identify and treat the tall growing stems.

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f. - Cutting and Trimming, No Herbicide Treatment 11 . .. . .: I* *1-Application: Target-Selective Cutting cuts vegetation as close to the ground as possible and no herbicides are applied. - -

Equipment: Chainsaw Limitations: No control of root system. Most northeastern hardwoods will resprout following hand cutting, some prolifically.

Buffer Zones: None Visual Effects: The cut slash is the primary visual effect. --Various slash disposal methods may be prescribed by the Forester to reduce visual impacts depending on adjoining land uses and sensitivities.

Full Discussion of Technique:

Application/Equipment: Cutting without herbicide treatment is primarily used to clear, undesirable species in areas of high sensitivity such as lawns, parks, and other buffer zones 92

E3-where only cutting or pruning is allowed due to deep public concern about herbicides; or easement or regulatory restrictions apply. In the absence of sufficient desirable vegetation, some tall growing species can be temporarily retained and pruned if necessary. The decision to trim, rather than cut, undesirable vegetation within a visual buffer zone should be made after considering the following criteria:

conductor clearance at the site

density and height of desirable vegetation

how visually sensitive and at what angle will the right-of-way be viewed (residence, park, road, river, etc.)

the relative number of individuals who may be exposed to view the site and the duration of their exposure

the probable activity of individuals at the time of view exposure Once adequate cover of desirable species is established on the site, the trimmed vegetation may be systematically removed. In some instances the cost to trim or recut a site may become fairly high. In those cases, the Forester will evaluate the costs of removing undesirable trees and replanting with desirable species.

Hand cutting is primarily accomplished using either a chainsaw or brush saw. Variations in the method of slash disposal recognized by National Grid include:

Cut only is when the slash remains lopped where it falls.

Cut and windrow is where the slash is disposed of by piling or windrowing.

Cut and chip is where the slash is disposed of by chipping. The chips may be disposed of on site or hauled away.

Note that in all cases, slash may not be left in an identifiable watercourse.

Limitations: Hand cutting is very labor intensive. When combined with the fact that tall-growing, undesirable species may be retained or rapidly regrow, hand cutting results in high per acre costs and shortened maintenance cycles. The lack of herbicide stump treatments to control sprouting (while warranted under certain site conditions) greatly reduces the long-range effectiveness of this technique.

Environmental Impacts:

Buffer Zones: The high selectivity of this technique causes little to no damage to non-target shrub species. However, the heavy resurgence of stump and root sprouts may cause the loss of compatible shrub and herbaceous cover over time, as undesirable stems increase in density and eventually suppress more desirable species.

Visual Effects: The impacts associated with this technique are the clearly defined cut edge of the right-of-way and the accumulation of drop and lopped or piled brush. These visual effects may be mitigated on some sites by the retention of desirable vegetation where it exists in the right-of-way.

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Site Conditions Favorable for this Technique: Cutting without herbicides and/or trimming may be proposed when the site is: .

1. a lawn, park, or other highly sensitive area; or

2. a no-herbicide zone to protect sensitive resources such as streams, ponds, lakes,

- or wetlands; or

3. a no-herbicide buffer zone adjacent to registered organic farm fields.

.: . . . ... I I . . . ..

- ' .I I... 1

. .; 11 ' i.

': ' 1: .:I '

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I ML3 g.: Mowing , - i .:,

Application: Non-Selective includes cutting and mulching of all vegetation.

Equipment: Large all-terrain vehicles with specialized mowing attachments or a heavy-duty 4x4 tractor with rear mounted brush-hog type mower.

Limitations: All other vegetation, both desirable and undesirable, is generally cleared by this operation. Selective management is limited to the operator's ability to save clumps or patches of vegetation by driving around them. Rough or rocky terrain cannot be mowed, and the heavy equipment may cause severe rutting on soft terrain. It does not control root systems and may result in prolific resprouting. Flying debris creates a hazard, limiting where the method can be used.

Buffer Zones: Vehicles should not be used in sensitive resource areas, including streams and wetlands, unless they are dry at the time of treatment.

Visual Effects: Completely removes all cover vegetation and produces a drastic short-term effect. Wilted, mulched vegetation, together with some exposed soil and rutting are the primary visual result of this treatment. -

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Full Discussion of Technique:

Mowing is a non-selective method that clears and removes allyvegetation, including frees, shrubs, and herbaceous material by iulching and disposing of the slash on-site. In some-instances, the operator may be able to save clumps or patches 'ofvegetation but only on a limited scale. Trying to avoid riumerous patches of vegetation with this large machinery quickly becomes impractical and inefficient and will push the cost of the operation up.

Applicationrqiuipment: Mowing is primarily intended for maintenance of the right-of-way in areas that have been deemed to'be "too sensitive" for herbicide application or where easement restrictions prohibit the use of herbicides. 'When terrain permits, mechanical mowing is more economical than hand-clearing methods. However, the lack of root control results in frequent reclearing, which then increases cyclical 'costs. The equipment includes a tracked 'or rubber-tired, all-terrain type vehicle mounted with a cutting'device capable of mowing small, woody vegetation.

Limitations: The treatment is limited to areas with flat to moderate topography and dry soil?-

moisture coniditions that will support the vehicle. The site must be free of big stones, logs, and large stumps. The hazard of flying debris limits where this method can be used, especially near highways or other public use areas where injury or property damage could occur. Land uses such as pasturing may create problems with fencing, slash'disposal, and the stubble, limiting th' effective use of this technique. Vegetatio'n that has become'too big can also interfere with' effective mowing.

Mowing is more suitable for gas rights-of-way where the management objectives require the" removal of all woody materials for cathodic testing and leak patrols. For example, woody vegetation can mask a gas leak from detection during routine aerial patrols. National Grid utilizes a three-year, cyclical mowing program to establish and maintainr gas rights-of-ways in a grassy or herbaceous condition. The higher safety standards together with the need for increased accessibilityjustify the cost of mowing to maintain the gas rights-of-way.

Mowing can only be selective by applicationr. In'other words, the operator may choose not to mow specific clumps or patches of vegetation.; However, since the mower's cutter head itself ranges from 6-10 feet in diameter, dependinig on the model, selectivity down to the plant level is not practical. It is also 'impra~ctical and inefficient for the operator to retain numerous patches of vegetation within the'riglt-of-way.' The riskobf working aiournd poles, towers, guy wires, fences, and other obstructions that require frequent backing and tumfihig of the equipment, outweighs any benefit from vegetation retention. This will also increase the price of the treatment to a point where hand cutting would become more appropriate.

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Environmental Considerations Buffer zones: Mowers should not be used in sensitive areas such as streams and wetlands, unless they are seasonally dry, due to the risk of excessive rutting. The hazard from flying debris limits the areas where this treatment may be used, and increases the buffers that are needed between the mowing equipment'and highways and other high-use public sites.

Wildlife: Mowing is a non-selective technique that eradicates desirable species as well as undesirable species. Mowing carries a distinct disadvantage in that it causes drastic change in the vegetative conditions'on the right-of-way. It is one of the most destructive vegetation management techniques for wildlife habitat.

Spill Potential: Mowing equipment has a high risk for spills and leaks from petroleum products, because of the intensity and vibration of the operation, and the numerous hydraulic lines and fittings that must constantly be monitored and maintained.

Visual Effects: The effects associated with this technique are sharply defined right-of-way edges, the loss of all woody vegetation, and the sight of shredded brush and stubble on the right-of-way floor.

Soil Erosion and Compaction: There is an increased risk of soil erosion and compaction with mowing operations as compared to the other maintenance techniques. This occurs due to the extensive travel along and across the right-of-way with heavy mowing equipment, as well as the occasional scuffing action of the mower along the surface. Both rutting and compaction can be minimized if mowing is accomplished when soil moisture is low. However, this often means mowing during the summer months when wildlife nesting and other ROW use is at its peak.

Site Conditions Favorable for this Technique:

Mowing should be specified when:

1. public concerns or easement restrictions prevent the use of herbicides, and

2. the cost of hand cutting is prohibitive, and

3. the site has been or should be maintained through mowing; or

4. the site has extremely dense undesirable vegetation that would require high volumes of herbicide to control, and mowing with a follow-up foliar treatment would reduce herbicide requirements and control resprouting, and

5. access with a heavy-duty all-terrain mower unit is feasible.

Note that mowing is the method of choice to maintain gas rights-of-way and allow access for testing, inspecting, and patrolling.

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h. Mowing and Cut Stubble Herbicide Application Application: Non-Selective cutting and removal of all vegetation with concurrent herbicide application to the cut stubble.

Equipment: Heavy-duty 4x4 tractor with a rear mounted Brown Brush Monitor mower unit.

Herbicide: Selective or non-selective products may be used at rates of approximately 15-20 mixture gallons/acre.

Limitations: Selective only by application. Rough or rocky terrain cannot be mowed. The simultaneous cut stubble herbicide application does control the root systems and minimize resprouting. Flying debris creates limitations on where the method can be used.

Drift: Drift is not a problem with this method due to the enclosed nature of the treatment.

Buffer Zones: Vehicles access into or through areas of sensitive resources, including streams and wetlands, is not permitted unless they are dry or stable at the time of crossing or treatment.

The use of herbicides shall be avoided within:

25-50 feet of streams, ponds, lakes, or wetlands Visual Effects: Complete removal of cover vegetation produces a drastic short-term effect. A sharp ROW edge and wilted, mulched vegetation are the primary visual impacts.

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Full Discussion of Technique:

As with conventional mowing, the Brown Brush Monitor is non-selective, clearing and mulching all woody vegetation it encounters, 'The unit is capable of cutting stems up to three' inches in diameter and immediately wipes' asmall quantity of herbicide oito the freshly cut stubble. This equiipment may be particularly' effective for sites with high-density, undesirable' vegetation where brownout from conventional foliar methods may-be a problem, or where other.

methods could actually increase herbicide. 'It may also be effective for converting mid-span wire zone sites from tall, 'dense shrub stands to more compatible herbaceous communities.

In' some instances the operator may be'able to save clumps or patches of vegetation,'butfonly 'on a limited scale. Trying to avoid or work around numerous patches with this machinery becomes impractical and inefficient and will increase operation costs. The use of this method is limited, by the'mower deck's inability to cut brush larger than 3 inches in diameter.

This method may also be effective to convert gas ROWs that have become overgrown by resprouting woody brush, and for establishing or maintaining access routes along electric' ROWs. The use of this equipment, combined with the cut stubble application, may lengthen the maintenance cycle and reduce future costs on sites that were either mowed 'or cut without herbicides in the' past. '

Application/Equipment: This cut stubble method may be used to maintain sections of the right-of-way that are sensitive to the brownout of conventional foliar methods, by mowing the undesirable'woody growth and immediately wiping a herbicide mixture onto the cut surface.

Where terrain allows, mechanical mowing is more economical than hand-clearing methods 'and with the 'herbicide application resproutirig is minimized. The equipment includes a heavy-duty 4x4 tractor with a rear mounted Brown Brush Monitor mower unit. The mower 'deck includes a*'

separate herbicide application compartment, immediately behind the mower compartment, where herbicide is wiped onto the freshly cut stubble by a system of brushes.'

Herbicide: The herbicide mix is a 4-6% mix that is applied at approximately 15-30 gallons/acre depending upon density. Either a selective or non-selective herbicide can be employed.

However, selective products that retain grasses or minimize impacts on the remaining herbaceous communities are preferred. At times a non-selective herbicide product may have a lower environmental risk or may require less active-ingredient per acre and could become the preferred mixture.

Limitations: 'The treatmentfis limited'to areas with flat to moderate topography and low soil moisture conditions to support the vehicle. The site must be' free of large 'stones, logs',' and big stumps. The hazard of flying debris is much lower with this tylie of brush mower as compared to the larger hydro-axe type mowers, because'the discharge chute better'directs the slash out and away from' the unit on one'side. However, it 'still limits the use' of this treatment near highways or areas where public injury or property daimage could occur. 'This ifiethod should not be used in active pastures when there are label restrictions associated with' herbicide use in pastures.

Large sized vegetation, over three inches in diameter, can prevent effective use of the mowing treatment.

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Environmental Considerations:

Drift: The Brown Brush Monitor applies herbicide to the freshly cut surface by wiping the mix onto the cut stubble in a separate compartment, immediately behind the mowing chamber. The application does not involve any airborne exposure, thereby eliminating the risk of drift.

Buffer zones: The Brown Brush Monitor mower shall not be used in sensitive areas such as streams and wetlands, and the application shall observe a 25-50 foot shut-off or buffer zone in these areas. These buffers can then be hand cut, or handcut and stump treated with approved aquatic products in accordance with permit requirements and the parameters discussed with each method.

Wildlife: As discussed in the section that describes mowing without herbicide use, the mowing technique is non-selective and eradicates desirable as well as undesirable species. It has a distinct disadvantage in that it dramatically changes the vegetative conditions on the right-of-way. In regards to wildlife habitat, mowing is the most destructive of all the treatments used.

Spill Potential: Mowing equipment has a high risk for spills and leaks from petroleum products, because of the intensity and vibration of the operation, as well as the numerous hydraulic lines and fittings that must be constantly monitored and maintained.

Visual Effects: The effects associated with this technique are a sharply defined right-of-way edge, and the sight of shredded brush and stubble on the right-of-way floor. Additionally, the herbicide application may cause a brownout effect to the remaining herbaceous vegetation immediately following treatment. This effect is generally short-term, and reduces as grasses and the herbaceous plants redevelop within the ROW.

Soil Erosion and Compaction: There is an increased risk of soil erosion and compaction from mowing operations compared to the other maintenance techniques. This is caused by the repeated travel along and across the right-of-way with mowing equipment as well as the occasional scuffing action of the mower along the surface. Both rutting and compaction can be minimized if mowing is accomplished when soil moisture is low.

Site Conditions Favorable for this Technique:

Mowing with a cut stubble treatment should be specified when the site:

1. has required mowing in the past and a cut stubble herbicide application is permissible; or

2. is within the wire zone, and mowing with cut stubble would reduce the herbicide.

requirements needed to convert the ROW to more compatible herbaceous species; or

3. requires maintaining or establishing access routes along existing transmission ROWs; or

4. is an existing gas ROW where undesirable woody vegetation has become a problem through repeat clearing without herbicides, and

5. is accessible with a heavy-duty 4x4 tractor and mower unit is feasible.

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H. Field Completion and Reportingi-Transmission work activities for vegetation management and danger tree removals are generally completed by contractor work forces. All contractor work is awarded based on approved System Purchasing procedures to the low price vendors.:

Contractor work completions are'reported on' the field inventory/work coh letion report and include site-by-site treatment methods, herbicide use, and treatment dates. The completed reports are submitted to the Division Forester for entry into the system wide Transmission Right-of-way (TROW) computer management program. An example of a cpm leted inventory with contractor c6ni1letions can be found in Appendix 8.

The computerization of this site-by-site data for each right-of-wia' provides effective analysis and tracking of-work activities and herbicide effectiveness on each right-of-way. The system further provides a hierarchy of reports,' -

summarizing information at the right-of-way, Regional, Division, or System level, for each scheduled year or for the entire cycle. These reports include information about herbicide use,'desirable and undesirable vegetation densities, management costs; etc.'

I. Landowner Notification National Grid acquires its transmission rights-of-way through fee purchase or easement, providing the right to 'conduct routine maintenance activities such as vegetation management, danger tree removal, and ingress and egress. All easement and 'fee ownership agreements that ar'e made with property owners are'documented

-and retained by the Right-6f-way Defraitmeent.

All retained documents are made available to affected parties upon request.

The company strives 'in every way possible'to maintain good relations with'the general public 'a' well 'as adja6e'nt or underlying property owners. As a matter of courtesy, reasonable attempts are made to contact and notify nearby residenfs when the movement of equipment or work operations may directly impact them.

Naitional Grid requires all vegettation management personnel to comply with Article 33 of the New York Environmental Conservation Law related to herbicide notification and posting requirements for landowners and the general public. These requirements are directly incorporated into the transmission Right-of-way"

Maintenance Specifications. In addition, informational brochures have been developed to help the public understand the program and the role 'of herbicides in vegetation management. Copies of the brochures are included as Appendix 9.

National Grid has further' developed an ACCESS database designed to identify individual property owners who request pers'onal notification prior to vegetation 101

management activities, including the use of herbicides. In accordance with DEC requirements, a customer must simply notify the utility in "ritingthat they request pre-notification and a permanent record will be created in the database. This system identifies special landowner agreements or land use requirements, including such activities as organic farming.

J. Customer Inquiry,and Complaint Resolution

1. Reporting Customer inquiries and complaints are initially received through the Customer Service Center or via customer e-mail on the National Grid website. Inquiries and complaints are then forwarded to the appropriate Division Forester for prompt customer contact and investigation.

2. Assessment Upon notice of a customer inquiry or complaint, the Division Forester shall promptly contact the customer to schedule and coordinate a field investigation, making the first attempt to resolve the concern. Based on initial contact, the Forester may direct the contractor completing the work to complete an incident investigation and make the first effort to resolve the inquiry in accordance with the terms and conditions of the contract. When an inquiry or complaint is handed off to the contractor, the Division Forester shall insure that the customer's concerns are promptly, thoroughly, and courteously addressed.

When property damage is involved, a field investigation is performed, and the Division Forester completes a claims report and forwards this report to the Claims Department for assessment and resolution with the property owner. If the claim involves significant property damage or alleged herbicide misapplication, the Division Forester shall notify the Manager of Transmission Forestry. In addition, if the complaint involves regulatory agencies, the Division Forester shall notify both the Manager of Transmission Forestry and the Environmental Affairs Department, together with local managers.

Complaints or problems of unauthorized dumping shall be handled in accordance with the Environmental Guidance EG-502, "Unauthorized Dumping" that is included in Appendix 11.

K Program Implementation

1. Determination of Work Force Transmission work activities are generally completed through contracting. Once the annual work plan is finalized and budgets approved, Division Forestry personnel together with senior management and labor relations, conduct good 102

faith discussions with the'lBEW Local 97 leadership on the use of contractors in accordance with the National Grid labor agreement; The Manager of Transmissioni Forestry shall provide ROW maintenance specifications, together with inventories and the necessary ffiaps to initiate the contract'bid priocess in acc6rdance wvith System Purchasing procedures. National Grid has implemented a unit price bid process for mainteniance of the ROW floor, under long-term,' ffulti-year'contracts. Specialized maintenance work, including danger tree removal and environmental restoration activities, are generally completed using hourly crews that are established 'through a multi-year bid process.

2. Crew Training National Grid requires all in-house and '6cntract supervision to be DEC fully certified applicators in accordance'with the provisions of Environmental Conservation-law 6NYCRR, Part'325.:Iii addition, National Grid requires that there be at least one fully certified applicator on each'crew: This person is generally the crew leader. All other application personnel are required to be qualified at either the apprentice or technician level, as defined by these pesticide regulations.

Certified applicators provide direct supervision to all applicators on each treatment crew. They also provide required training to commercial pesticide apprentice applicators. Certified technicians may work under indirect supervision of certified applicators when using general use pesticides. Certified technicians cannot supervise or train'apprentice applicators. '

All certified applicators and technicians are also required to complete regular re-certification training, in order to renew their pesticide applicators license.

'Transmission foresters work with other utilities, as well as the Department of

Transportation, the DEC, the'PSC, Comell Cooperative Extension, chemical manufacturing representatives, and other educators to develop and sponsor an annual refresher training program for right-of-way applicators known as Category 6 training. This training exceeds the minimum DEC requirements by annually providing applicators with up to eight hours of training on regulatory updates, landowner notification and posting, and DEC reporting. The training also' includes changes and enhancemen'ts'to treatment methods,' and provides updated";:

information on new technologies and products. Category 6 is also used to keep crews current with continuing or new research'developments in right-of-way management. -

The Manager of Transmission Forestry and/or the Division Forester'shall also conduct annual crewtraining with all treatment personnel and supervision at the start of each season. This training reviews the approved application methods, herbicide mixtures, and criteria for matching a treatment method to the'site 103

Xa-requirements. It emphasizes attention to environmentally or visually sensitive areas, and shows how to implement appropriate buffer zones. Special requirements, such as DEC wetlands or endangered species considerations are discussed, and DOH public health issues related to drinking water supplies are identified. The inventory is reviewed to identify site location and treatment requirements, including any special notes incorporated on a particular site. In an effort to achieve continuous improvement, the success and the problems related to previous year's work are reviewed, with special emphasis on areas of concern related to public or customer notification, communication, or sensitivity. In the future this training will also incorporate detailed training in mid-span clearances requirements, shrub identification, and selective implementation of the wire zone/border zone concept.

The Division Forester will continuously monitor the success of this training, and initiate remedial training as required to enhance crew knowledge, skills, and performance. The success of the Program in achieving these training goals is further incorporated into the annual field review process of the Manager of Transmission Forestry, Division Forester, and the PSC environmental staff The emphasis of the training is to inform and educate field crews and their supervision in the overall goals, objectives, and strategies of this long-range Program, and insure its successful implementation.

3. Contract Specifications The Transmission Right-of-way Maintenance Specification is designed to insure the successful implementation of the terms and conditions of this long-range management Program. This specification is periodically reviewed and revised to incorporate program modifications and enhancements. These changes are then set forth in contract documents and communicated to contractors through the pre-bid and crew training processes. The commitment of the program to an ecologically balanced approach, using highly selective herbicide application methods and following the principles of integrated yegetation management, are also communicated to all vendors through the pre-bid process.

Following the award of maintenance activities to the successful bidder(s), in-field training is conducted by Division Foresters and the Manager of Transmission Forestry to ensure full training and communication of program goals, objectives, and strategies, together with specification requirements down to the applicator level. In order to abide by specification requirements, contractor personnel must have the ability to distinguish between undesirable and.compatible species.

Various levels of in-house and contractor supervision closely monitor field treatment activities to insure compliance with the specifications.

104

4. Supervision The Program requires various levels of responsibility and supervision to be successful. It also requires all levels of supervision to by actively involved in the training, implementation, and monitoring processes. Of these, proper training is the most important element for successful implementation. '

Manager of Transmission Forestry '

The Manager of Transmission Forestry is responsible for the development and

'implementation of system vegetation' management policies an'd procedure's, as defined by this long-range Transmission Right-of-ivay Management Program.

This includes system oversight of the measures'and'activities'necessary to meet the requirements of the prograrn.'

Division Forester ' '

The'Division Forester is responsible'for the field implementation of transmission right-of-way managenerit activitiesa'and practices necessary to 'accomplish the goals, objectives, and strategies of the long-range Transmfission Right-of-way Management Progranti.' This includes 'completing field inventories' and/or supervising the inventory reporting process. They direct and supervise all right-of-way maintenance, clearing, tree trimming, danger tree removal, environmental restoration, and other related activities!'within their assigned Division, to assure compliance with the specifications and the Program.

The Division Foresters are experienced professionals'trained in the identification of desirable and undesirable'vegdtationr. They are fully certified applicators as defined by the DEC pesticide applicator regulations.

Contract Supervisor -

Each vegetation management'contractor shall provide a trained and qualified supervisor that fully understands the goals, objectives, 'and'strategies of the' program, as defined by the specifications. Each supervisor shall be 'a DEC fully certified applicator who is capable of distinguishing between desirable and undesirable species. -

Sprav Crew Leader ' ' ' ' ' ' "" ' ..

Each vegetation management crew' shall be 'directed and coordinated by an' on-site, DEC fully certified applicator'who' has specific responsibility for direct

'supervision of those'individuais assigned to clearing and treating. The crew leaders shall be fully knowledgeable'in species identification and selective IVMv principles and'practices.' Spray'crew leaders are responsible for'assurin'g that nozzle operators are trained and proficient in carrying out the specifications. The 105

supervisor for the crew leaders is responsible for assuring that each crew leader is properly handling their duties and responsibilities.

On-the-iob Training of Nozzle Operators Each crew leader spends sufficient time with each new applicator when they start work to assure they are trained in the appropriate application procedures and identification techniques. Nozzle operators are trained on the job and are constantly supervised by the full-time crew leader during treatment operations.

Generally, each site or right-of-way contains a mixture of species that must be controlled and others to be retained. The range of targeted species often changes from site to site along the ROW, with some small tree species and taller growing shrubs being too tall to be retained under some mid-span sites. These same species may be compatible at other mid-span sites or along the ROW edge.

Woody plant lists are incorporated into the specifications to serve as a guide in determining whether or not to treat. It is the responsibility of the crew leader, together with contractor supervision and the Division Forester, to train and instruct each member of the crew in the proper implementation of the wire zone/border zone principles and IVM practices. The crew leader generally accomplishes the site-to-site training by routinely pointing out these species and clearance differences as the treatment process moves along the ROW.

This method of training has widespread use throughout the industry and has proven highly effective. The degree of effectiveness fluctuates with the degree of emphasis placed on this issue by supervision. National Grid is committed to selective treatment following sound IVM and ecological principles and intends for our applicators to implement practices and procedures that fulfill those objectives.

5. Program Monitoring The Division Forester is responsible for monitoring day-to-day field maintenance activities. The frequency of field visits depends upon the type, location, and complexity of the work.

L. Measurement of Program Effectiveness The effectiveness of the program is continually monitored, tracked, and reported through a number of indices, including reliability, costs, herbicide use, desirable and undesirable densities, and cycle length. Costs are accurately measured by costs per acre, per year for maintaining the right-of-way over the length of the cycle and life of the line. Herbicide use continues to be measured in terms of gallons of herbicide concentrate per treated brush acre. National Grid has used concentrate gallons and concentrate gallons per acre since it was first required to submit an annual herbicide use report to the PSC in 1978.

106

National Grid is required to submit an annual report to the PSC by March 31 of each year. This report shall include the following:

A summary of the acres scheduled for each year and the actual acres treated by line.

A summary of the acres treated by technique.

A summary of cost per acre by techniique.

A summary of herbicide'use for each technique.

A summary of spot trim and danger tree work activities.

A summary of environmental restoration and access road activities.

A copy of the tentative work plan for,the year ahead.

A summary of acres treated by technique within the Adirondack Park.

A copy of the 2002 annual report is included in Appendix 10.

M. Regulations, Permits and Approvals This Program incorporates the special environmental and vegetation management concerns of various Article VII electric and gas projects into the management goals and objectives of this Program. It will continue to uniformly and consistently apply industry best management practices for environmental and vegetation management to all electric and gas transmission facilities, including Article VII projects. Appendix 1 identifies the special Article VII concerns for each electric project and Appendix 2 addresses the gas projects. -

Appendix 12 includes special conditions which apply within the Adirondack Park.

National Grid policy requires compliance with all applicable federal, state, county, and municipal laws, rules, and regulations; and these requirements are incorporated into the terms, conditions, and specifications of all contracts. Article 33 of the New York State Environmental Conservation Law form the basis for Part 325 and 326 of New York State Code of Rules and Regulations are regulations that pertain to herbicide use for vegetation management activities. Other pertinent regulations govern herbicide application in wetlands and compliance with endangered species regulations. ,

Article 24 of the NYS Environmental Conservation Law (ECL) covers right-of-way maintenance activities in wetlands, while Article 15 of the ECL addresses activities in other regulated water bodies. A combination of a Standard Activity Permit for herbicide applications (see below), a General Permit for other "minor" maintenance activities, and occasionally, a-U.S. Army Corps of Engineers Nationwide Permit #3 are necessary before completing maintenance activities in wetlands, streams, or other water bodies. The Army Corp Nationwide Permit is needed for fill or excavation activities associated with the operation and maintenance of the line, including 107

Ea-maintenance, repair, or replacement of culvert and stream crossing devices. New installations may require a Nationwide 12 Permit, or even an individual permit.

It is the specific responsibilities of the Environmental Affairs and System Transmission Forestry Departments to ensure and expedite compliance, including fulfilling any public posting and notification or regulatory permit requirements. The Company has developed two Environmental Guidance documents to ensure that all pesticides and herbicides are handled and applied in accordance with the regulations and that herbicide spills are promptly reported. Copies of the Environmental Guidance "EG-504, Pesticide and Herbicide Application," and "EG-202 Herbicide Spill Reporting" are included in Appendix 11.

The Manager of Transmission Forestry is charged with primary responsibility for business registration, herbicide training and safety, and annual herbicide use reporting under existing pesticide regulations.

The Environmental Affairs Department (EAD) is responsible for maintaining databases and GIS systems that identify, locate, and protect natural and cultural resources. They complete the annual permit application for vegetation maintenance activities in regulated'wetlands, and provide expertise and DEC liaison on endangered species issues.

1. NYS DEC Herbicide Application Permit for Wetlands National Grid was the first New York State utility to submit for and receive a "Standard Activities Permit" for its annual vegetation management program in regulated wetlands. This process was first initiated by the EAD in 1999, and its terms and conditions remain in effect through June 10, 2008.

In accordance with this "Standard Activities Permit," the Environmental Affairs Department prepares an annual regulated wetlands permit submittal to the DEC that includes the tentative annual schedule of lines planned for maintenance in the year ahead. It will include an electronic geographic information system (GIS) or equivalent map file that identifies the line route, road crossing, and other pertinent land features, and the location of regulated wetlands that are crossed by or in proximity to the right-of-way. EAD shall also publish any public notice announcements required by the wetlands permitting process. EAD will obtain the required DEC permit and forward it to the Manager of Transmission Forestry who will, in turn, distribute it to the appropriate Division Forester and contract supervisor.

Once field applications begin, the Division Forester provides weekly updates to the Regional DEC offices identifying lines that are scheduled for work in that particular week. This report will be submitted to the Regional DEC Natural Resource Manager and Pesticide Inspector. The report is generally submitted at the beginning of the. week to communicate anticipated work 108

plans. Actual work can vary from the expected work plan due to changes in weather 'conditions, crew performance, etc.

2. NYS DEC Wetlands and Streams General Permit 98-01 In 1998, the EAD negotiated a General Permit for routine utility work activities with the DEC, replacirin a burdensome process that required individual permitting of activities. This permit was the first of its kind, incorporating 44 separate maintenance activities into a single permitting process. 'Each minor activity included in this permit is associatediwith a set of best management practices and is annually measured for compliance and reporting by EAD: The perrnit is good through April 1, 2003.

3. NYS DEC Endangered Species Notification

EAD shall also prepjare a"voluntary 'submittal to the DEC Natural Heritage Program to provide an electronic GIS or equivalent map file that shows the line route, road crossings, rid' other pertinent land features. The Natural Heritage Program will us'e this'information to identify kndw'npopulations of rare, threatened, or endangered species that may be found within 150 feet of

- the righi-of-way and then 'communicate those locations to the Company.

The' Environmental Affairs and Transmission Forestry Departments shall then work collaboratively withithe DEC Endangered Specie's Unit to determine the potential risks and benefits'of right-of-way management activities.' The program's procedures and practices strive to protect known populations of threatened or endangered species so as to avoid and prevent incidental take.

The program is committed to the philosophy that most ROW'management activities will either have a positive effect on endangered species and critical habitat, or can be modified slightly to enhance critical resources.

Once a plan of action is identified, the Manager of Transmission Forestry and the Division Forester are responsible for training th6 treatment crews in the appropriate work methods.

4. Voluntary Department of Health'Notification' ;

The Division Forester shall prepare a voluntary submittal to the NYS Department of Health (DOH) to communicate routine transmission maintenance activities, 'line locations,' treatment'methbds, and herbicide mixtures. The notification shall be provided to the appropriate county or region by early s'ptiig. 'The submittal shall include'a list of lines scheduled for maintenance' in the coining year together with the annual herbicide code sheet that identifies approved treatment mfethods and herbicides or herbicide'tlank mixtures. Copies of the work specifications will be available upon request.

109

AU-The plan shall also include a GIS map or other suitable map file showing the line route, that the DOH may use to identify known public water supplies located near the proposed work. The name and contact number for the appropriate Division Forester shall be included to provide each DOH officer with a direct communication point for questions concerning the proposed wo-rk and to help identify well points to the Forester.

Information that is provided about drinking water resources will be communicated to the field crews by the Division Forester.

In order to insure that "clean" water resupply trucks are used, field crews will not be permitted to transport herbicide or other herbicide application equipment on these units. In addition, all equipment used to draw water from any water source shall be equipped with an effective anti-siphon device or water break to prevent back flow.

5. Public Notification and Posting Procedure for Herbicide Application The program requires compliance with all DEC pesticide notification, posting, and annual reporting requirements through its specifications.

The Manager of Transmission Forestry shall annually secure the required business registration permits for each Region/Division. The Division Forester and System Transmission Forester are responsible for submitting the annual pesticide use report directly to the DEC for herbicide that is applied under the direct supervision of their license. Each contractor shall submit reports to the DEC for their application work on National Grid rights-of-way. They shall also provide sufficient, timely reports to the Division and System Foresters to enable preparation of all work completion, herbicide use, and annual PSC reports.

6. ISO 14001 Considerations In preparing the Company for ISO 14001 certification of its transmission and distribution system, the above regulatory requirements have been summarized into a Corporate Environmental Guidance document. A copy of this document is included in the Company's Electric Operating Procedures and is available for review on the Company's web page.

N. Testing of New Material and Mixtures National Grid is committed to use only properly labeled herbicides the have been approved for the specific uses by the appropriate state and federal authorities, and to use them in a prudent, economic, and environmentally conscious manner.

110

Under approved experimental conditions, National Grid has and will continue to field test and research promising new herbicide and non-herbicide products, treatment methods, and application equipment for approximately two growing seasons. Upon successful field testing, new products, tank mixes, methods, or equipment will then be introduced into the program on a more operational basis. The Manager of Transmission Forestry will cooperate with suppliers, researchers, and others to design, apply, and evaluate field tests.

0. Research The success of vegetation management programs in New York today is directly related to the research that has been jointly conducted through ESEERCO over the past two decades. The importance and role of research in the development of this Program is integrated throughout this document and a complete summary of the ESEERCO and National Grid funded research is included in Appendix 4.

National Grid will stay abreast of regional and national research developments related to the environmental and ecological benefits of herbicide use, as well as and the impacts of various herbicide and non-herbicide treatment alternatives. Where gaps in right-of-way management knowledge and data exist that may improve Program performance, we will seek strategic research partners from across the state and the region to share and equitably distribute the benefits and economic burdens of research.

P. Program Review While the program is under continuous review and improvement, National Grid will periodically review and assess the plan no less than every six years or two complete treatment cycles, which ever comes first. Areas of assessment will include but not be limited to reliability, cost, herbicide use and complaints. Any changes proposed to the plan will be brought to the attention of DPS Staff. Staff will refer those minor

changes, which will not cause significant adverse impacts to the environment (including public health) or reliability, to the Secretary of the Commission. All other changes will be considered major and will be referred to the Commission for action pursuant to the State Administrative Procedure Act.

111

APPENDIX 1

~.ase.

26573 May 16,1975 FIPNULt] rvAWU-rtPALAjUN tK% DUNKIRK-FALCONER 160 26520 December 15, 1975 .

i. : No HOMER CITY - STOLLE HOMER CiTY. STOLLE 37

.26729 December 12, 1976 - No WELLSVILLE - ANDOVER SOUTH WELLSVILLE - ANDOVER 541 I

.26923a July, 22, 1976 & .Yes ADIRONDACK LiNE; Tower 15 Io WARRENSBURG - SCOFiELDb ROAD 10 j August 19,1977 .Warrensburg

.26923b December 15, 1986

No -ADIRbNDACK LINE . NORTH CREEK - WARRENSB'URG 5" . .

70073 April 18, 1980 No COFFEEN'- WEST ADAMS 2* -.

70137 Augist 8, 1983 - No ~~~.COLTN - ENNiSON 4 &5 jDENNISON - COLTON '4& 5 .

26465 February 7, 1975 Yes .MCINTYRE- BROWNING ALCOA- NORTH OGDENSBURG 13 - MCINTYRE 9

27290 August 14, 1978 Yes *,LECOLBY - LAKE PLACID LAKE COLBY -.......LAKE PLACID.. ............

3 ......

126251 a February 8, 1974 Yes jVOLNEY . .. ..... . ...........

- MARCY VOLNEY -.MARCY 19 262 .F e.ruay.. 1 ..... No JOSWEGO - DEWITT CLAY - DEEWIT 13; OSWEGO - LA.FAYETE 17

.. . ... . ... ... ... ...... ... .. ..... ............. . ... ..... ...... :.I. ..

26251c February8, 1974 .. No E"WEG° - VOLNEY 1i& 12 .

26251d February 8, 1974 No DEWfTT-LASFAYET E22

!26482 March 22, 1976 . ... . .......

No N o. *LAFAYETTE - OAKDALE LAFAYE -.OAKDALE 4

. !70346 September 4, 1986. No ONEIDA - CORTLAN'D 3- -

70068 August 12, 1983 Yes .NINE MILE 2 -VOLNEtY NINE MILE 2 SCRIJA 23- VOLNEY20 & 21 -CLAY 6 92-T-0114 Auigiust'20, 1992

Yes INDEPENDENCE - CLAY INDEPENDENCE.-SCRiBA 25- CLAY 26 .;

1'26423 August 1, 1974 : No NEW SCOTLAND - REYNOLDS REYNOLDS ROAi - AlPS ROAD 3 & 17

WESTERN REGION ELECTRIC TRANSMISSION LINES:

HOMER CITY - STOLLE 37 (Case 26520) {Homer City - Stolle Road 37)

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 37.5-mile 345 kV facility.

FINLEY (sic FINDLEY] ROAD - FALCONER (Case 26573) (DUNKIRK- FALCONER 1.60}

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 27-mile 1 5 kV line off the DUNKIRK - SOUTH RIPLEY 68 line.

SOUTH WELLSVILLE - ANDOVER (Case 26729) eNELLSVILLE -ANDOVER 541)

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this I 1-mile 115 kV line.

CENTRAL REGION ELECTRIC TRANSMISSIONLINES:

ADIRONDACK LINE (Case 26923) (Tower 15 to Warrensburg aka WARRENSBURG -

SCOFIELD ROAD 10 and NORTH CREEK -WARRENSBURG 5)

ITEM 1: The Case directed that in the section of this 37.5-mile 115 kV line between Tower 15 and the saddle between Swears Mountain and Birds Nest Mountain, identified as visually sensitive, specific treatment plans were to be described for each fuiture management cycle.

ACTION: The Company will satisfy this requirement pursuant to GOAL D, OBJECTIVE I of this revised long-range right-of-way vegetation management plan.

ITEM 2: The Case precluded the Company from using foliar applications of herbicide.

ACTION: The Company will not use high volume foliar applications on these sites. It will manage vegetation in accordance with revised long-range, right-of-way vegetation management plan GOAL D, OBJECTIVE I and the site selection criteria for highly selective low-volume (backpack) or stump treatment methods.

COFFEEN STREET - WEST ADAMS 2 (Case 70073)

There are no specific issues that are not folded into the current long-range ROW Vegetation Mfainagement Plan for this 14.2-mile 115.

COLTON - DENNISON 4&5 (Case 70137) {DENNISON-COLTON 4 &5)

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 27.2-mile 115 kV line.

INDEPENDENCE - SCRIBA 25 - CLAY26 (Case 92-T-01 14)

ITEM 1: Order X2 28 for this 29-mile 345 kV line stated thatt 'there shall be no

.brushhoggingor mowing within a DECregulatedwetland except where the treatment site is dry at the tine of mowing, and as provided in the EM&CCP or long term right-of-way managementplan approvedby the Commission.'

ACTION: The Company will not mow in wetlands if wet.

LAKE COLBY-LAKE PLACID (Case 27290) (LAKE COLBY- LAKE PLACID 3}

ITEM 1: 'An Order precludes the use of herbicides' in a setion of this 10.3-mile 115 kV line in the Four Corners "Forever Wild" Area, making reference to a' Temporary Revocable Permit needed for that vegetation management..

ACTION: The Company will not apply herbicides between Structure 82 and Structure 83.

MCINTYRE - BROWNING (Case 26465) {ALCOA - NORTH OGDENSBURG 13 -

MCINTYRE 9}

-ITEM 1-A Order restricted the' use of herbicides near stream crossings on this 38.5-mile 115 kV line based on NYSDEC concerns.

ACTION: The ROW Vegetation Management Plan contains an explicit discussion'of wetland and streaniside buffer zones for herbicide application.

Applications will be conform to our long-range'ROW Vegetation Management Plan and NYSDEC Standard Activities Permit.

ITEM 2: An EM&CP restricted the use of stem foliar herbicide treatments on certain areas pending listing of those sites and approval in the specific ROW rnanagement plan.

ACTION: The ROW Vegetation Management Plan revision updates and supercedes the individual plan, and identifies the criteria by which site-specific treatments are implemented. ,,

NINE MILE 2-SCRIBA 23 (Case 70068) {Nine Mile 2-Scriba 23-Volney 20 & 21).

ITEM 1: An Order required th'aibrushland was o be' retained from 100 feet west of the rail line and south of Lake Road for a distance of 50 feet.,

ACTION: The Company will retain a scrub shrub vegetative screen in front of the Scriba Substati6n.' '

ONEIDA - CORTLAND 3 (Case 70346)

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 45 miles of 115 kV ROW.

VOLNEY - MARCY 19 (Case 26251a)

ITEM 1: The line is constructed on a NYPA easement.

ACTION: The Company acknowledges ITEM 2: 'No herbicide' use restrictions are placed on sections of the line in accordance with NYPA rules.

a-ACTION: The Company has identified these segments and their special treatments in our, operating documents and inventories.

ITEM 3: Several long-term R&D project commitments have been made in Oneida County segments.

ACTION: The Company has identified these segments and their special treatments in our operating documents and. inventories.

OSWEGO - DEWITT (Case 26251 b) {CLAY - DEWIlT 13; OSWEGO - LAFAYE17E 17)

There' are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 50-mile 345kV line that was approved with several others in this Case.

OSWEGO-VOLNEY 11&12 (Case 26251c)

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 13.5-mile facility that was approved with several others in this Case.

DEWITT - LAFAYETTE 22 (Case 26251 d) (LAFAYETTE - DEWITT 22)

This 345 kV line was compartmentalized in this Case. On this segment there are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan.

LAFAYETTE - OAKDALE 4 (Case 26482) {LAFAYETTE - D'EWlTT 4)

There are no specific issues that are not folded into the current long-range ROW Vegetation Management Plan for this 40-mile 345 kV facility.

EASTERN REGION ELECTRIC TRANSMISSIONLINES:

NEW SCOTLAND - REYNOLDS ROAD 3 &17 (Case 26423) {REYNOLDS ROAD -

ALPS 1}

There are no specific Article VII requirements or conditions affecting vegetation maintenance for this 12-mile 345kV facility. Vegetation management shall conform to the System-wide plan.

APPENDIX 2 GAS CASES

_ _ l I I Specific Case Number and Date Field Case Name Facility Operating Name II 70079 July 16, 1980.

Conditions No COMMISSARY CREEK I

IPIPELINE 31 (Commissary Creek)

., 7--

. 1.-

, -, .I

. I i

89-f-04 cmber18,1990 Yes HOLCOMB ROAD - CARTHAGE PIPELINE 56 (James River Paper CoGen) .... .. . - . I 89-T- 58july 12, 1990 3 HALL ROAD - OSWEGO . PIPELINE 58 (Hall Road - Oswego) - . .... . .- .. -- 0 692-T-0252 August 20, 1993 Yes-' PHOENIX - SCRIBA - OSWEGO__ PIPELINE 63 (Sithe Independence)

92-T-0271 July 19, 1993 Yes CROGHAN -WILNA PIPELINE 64 (Iroquois Tap - Carthage) . . I

91-G-0532 March,15, 1993 . No BRISTOL MEYERS SQUIBB PIPELINE 65 (Bristol CoGen)

.91-T7-1093 March 17. 1992 No VICKERMAN HILL - ILION PIPELINE 60. (Vickerman Hill - Ilion) --- _--. -1 90-T-0594 September 6, 1990 l Yes SHERRILL .

PIPELINE 61. (Oneida Co-Gen)

IiI I

.- (Gc R . I

'26458 November 8,-1973' No SARATOGA - SOUTH GLENS PIPELINE E-31 (Gick Road) :-. i I FALLS :' d - .. I ;- .. I , I I

',70134 April 20, 1983 No FREEMANS BRIDGE - - PIPELINE E-8A I 7 1 - -r

. No 70248 October 31, 1984 . i o ROHTERDAM - GE PIPELINE E-7-? (Rotterdam - GE)

T-0834 March 7,1991 '.-' I

- No I- SOUTH GLENS FALLS/KAMINE PIPELINE E-12-9 SOUTH GLENS FALLSIKAMINE SERVICE

, I I (Kamine/Besicorp South Glens Falls)

90-T-1133 May 9, 1991 No - SCHODAK - FORT ORANGE PIPELINE .E-32 (Schodak - Fort Orange)

.92-T-0i01 July 7, 1992 No BASF/Hadson __,__ PIPELINE E-35 (BASF/Hadson)-," =

92-T-1207 April 7, 1i993 - Yes -INDECK-CORINTH PIPELINE E-33 (Indeck-Corinth) _

01-T-1160, PENDING L.i

_ROTTERDAM

_ - CHARLTON PIPELINE E-36 I

AL-CENTRAL REGION GAS TRANSMISSION LINES:

PIPELINE -31 (Case 70079) (COMMISSARY CREEK - ONONDAGA HILL REROUTE)

There are no specific vegetation management restrictions.

PIPELINE 65 (Case 91-G-0592) (Brstol Meyers Squibb)

There are no specific vegetation management restrictions.

PIPELINE 56 (Case 89-T-042) { James River Paper CoGen aka WATERTOWN -

CARTHAGE}

ITEM 1: Order Xe 30 precludes brush hogging.or mowing within a NYSDEC-regulated wetland except where the treatment site is dry at the time of mowing.

ACTION: The Company will not mow in wetlands if wet.

PIPELINE 58 (Case 89-T-058) (HALL ROAD - OSWEGO)

ITEM 1: Order Mt 29 of this 12.5-mile facility restricted herbicide usage in buffers or wetlands.

ACTION: The Company will adhere to Objectives and Criteria of the current long-range ROW Vegetation Management Plan.

ITEM 2: Order N° 30 precludes brush hogging or mowing within a NYSDEC-regulated wetland except where the treatment site is dry at the time of mowing.

ACTION: The Company will not mow in wetlands if wet.

PIPELINE 63 (Case 90-T-0252) (SITHE INDEPENDENCE)

ITEM 1: Order K2 1(g) of this 27-mile facility precludes brush hogging or mowing within a NYSDEC-regulated wetland except where the treatment site is dry at the time of mowing.

ACTION: The Company will not mow in wetlands if wet.

ITEM 2: Order KN 32(a) restricted herbicide use to following practices used on electric ROW's.

ACTION: The Company will adhere to Objectives and Criteria of the current long-range ROW Vegetation Management Plan.

PIPELINE 64 (Case 92-T-0271) {Iroquois Tap - Carthage}

The restrictions this 14.8-mile facility mirror those given above for PIPELINE 63 (Case-90-T-0252).

PIPELINE 60 (Case 91-T-1093) (VICKERMAN HILL - ILLION}

There are no specific vegetation management restrictions.

PIPELINE 61 (Case 89-T-0594) (ONEIDA COGEN)

ITEM 1: Order N2 1(g) of this 5,750-LF facility precludes brush hogging or mowing within a NYSDEC-regulated wetland except where the treatment site is dry at the time of mowing.

ACTION: The Company will not mow in wetlands if wet.

EASTERN REGION GAS TRANSMISSION LINES:

PIPELINE - GE (Case 70248) {RO1TERDAM -GE)

There are no specific Article VII requirements or conditions affecting vegetation maintenance for this 1400 LF facility that is mostly beneath pavement on GE's complex.

FREEMANS BRIDGE (Case 70134) {PIPELINE E-8A}

There are no specific vegetation maintenance restrictions on this 1070-foot facility PIPELINE E-31 (Case 26458) {Gick Road aka Saratoga - South Glens Falls)

There are no specific vegetation management restrictions.

PIPELINE E-32 (Case 90-T-1133) (Schodak-Fort Orange)

There are no specific Article VII requirements or conditions affecting vegetation maintenance of this 2.7 miles long facility.

PIPELINE E-33 (Case 92-T-1207) (Indeck- Corinth)

The restrictions this facility mirror those given above for PIPELINE 63 (Case 90-T-0252).

PIPELINE E-35 (Case 92-T-0401) (BASF/Hadson)

There are no specific vegetation maintenance restrictions on this 1.8 miles long facility.

PIPELINE E-7-1 (Case 70248) (Rotterdam - GE)

There are no specific vegetation maintenance restrictions on this 1400-foot facility.

PIPELINE - SOUTH GLENS FALLS/KAMINE SERVICE (Case 90-T-0834)

{Kamine/Besicorp South Glens Falls)

There are no specific vegetation maintenance restrictions on this 2050-foot facility.

PIPELINE E-36 (Case 01-T-1 160) (Putnam Road - Charleton)

Pending (on Spier Falls - Rotterdam 115 kV ROW)

JAPPENIX Final Draft: March 7,2002

-APPLICATIONS OF INTEGRATED PEST MANAGEMENT TO ELECTRIC UTILITY RIGHTS-OF-WAY VEGETATION MANAGEMENT IN NEW YORK-STATE'-,.

Environmental En'e'rgy -Alliance -of New York Land Use Subcommittee, Committee Position Paper

'. - . . ...... . : .S - -.......................... l The Environmental Energy Alliance of New York is an association of electric Cop. Distr~ibuition' (T&-D) companies .W and electric' ....................................

gas Transmission and ...so Ga . Me and

.i ..

generating companies that provide lenergy services' in the State'of New:York.-

This positio paper was prepared by, the Land Use Subcommittee of the T&D Committee whichcurrently r Pesents hebe Husn a&Eetri Coprtion, Cons~olidated Edison Company of New YoErkLvongIslanalPower Authoritye New York Powiner'authority,n ew Yeork' State'Electric &-Gas Corporation; Niagara Mohawk; Orange- & Roc'kland' Utilites,TandmiRocester as DiEletiCtion For more infori'ation aboutthisiPosition Paper splerarsed byotnLtact UKevi T.McLomithlin se the System Foresterlor the New York Power Authority at P.O. Box 200, GilboaNewY York 12076. Tel. (607) 588-6061 ext. 6903, Fax (607) 588-9826 or e-mail--

Kevin.Mcloughlin~nypa.gov.

Executive Summary As a matter of public safety and system' reliability, electric utility rights-of-way (ROW) vegetation managers have a continuing need to preclude the establishment and subsequent growth of tree and tall woody shrub species that are capable of growing up into or' even close to overhead electric lines. The members systems of the Environmental Energy Alliance of New York (EEANY)

Transmission & Distribution (T&D) Committee employ the process of Integrated Pest Management (IPM) toensure that tall growing trees and woody shrubs do not interfere with these critically important electric power transmission facilities. IPM balances the use of cultural, biological, physical and chemical procedures for controlling undesirable tall growing woody species on utility ROW. These IPM procedures, as practiced by the New York State electric utility industry, can be more appropriately referred to as an Integrated Vegetation Management (IVM) strategy. One of the important components of the IPMIIVM process is the selective use of herbicides to curtail the growth of undesirable tall growing species while preserving, to the extent practical, the lower growing vegetation on"the ROW to act as a biological deterrent to thee future re-establishment of trees.

The EEANY Land Use Subcommittee members halve been practicing IVM policies and programs for well over two decades on' those portions of the approximately fifteen thousand circuit miles. encompassing over one hundred thirty thousand acres of overhead transmission line ROW that 'require the vegetation to be managed. IVM is'an environmentally compatible activity that is cost effective. and has all' the elements of a conscientiously applied IPM strategy. This paper discusses the application of IPM to. contemporary electric: utility ROW vegetation management practices in New York State today as a.truly ecologically based approach to pest management.

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APPLICATION OF INTEGRATED PEST MANAGEMENT

- TO ELECTRIC UTILITY RIGHTS-OF-WAY VEGETATION MANAGEMENT Integrated Pest Management (1PM) is a process that balances the use of cultural, biological, physical and chemical procedures for reducing pest populations to tolerable levels. 'Rather than'relying solely on chemicals (or eliminating 'chemicals completely) IPM seeks to produce a combination of pest control options that are compatible with the environment, economically feasible and socially tolerable. The control of vegetation, i.e., the contemporary management of vegetation, on electric utility line rights-of-way (ROW)' readily accommodates itself to an IPM process. This paper describes how the member electric systems of EEANY T&D Committee have been actually practicing an IPM 'strategyfor about tvo decades. However, that strtegy Fan be more appropriately referred to as an Integrated Vegetation Management (IVM) strategy: ' be BACKGROUND - -

In New York State after a forested landscape is cleared, or when a cultivated field is abandoned, the natural vegetation type that will ultimately re-occupy the site and dominate the area will be tall growing trees.

When the cleared area is an electric utility ROW, these resurgent trees can grow too 'close io the overhead electric lines. When this occurs, there is the potential for an electrical discharge from the electric line thiough the air to the tree and then to the ground. iThis is knowni as a "line to ground fault" or "flish-over." 'The result of a line to ground fault is an instantaneous break in electric service and a potentially very dangerous 'situation on the ground in the' immediate vicinity of the high voltage discharge. Therefore, as a matter of public safety'and system reliability, utility ROW vegetation' managers have a continuing need to preclude' the establishmeint 'and subsequent growth of those tree species including some tall 'growing'woody shrubs' that are capable of growing into or even close to' the electrical lines.2 -Utilities ensure that tall growing species 'do not interfere with electric lines by committing to a long-term ROW vegetation'rnanagement program.

INTEGRATED VEGETATION MANAGEMENT AS AN IPM STRATEGY

.. ! . - - S ' '; ; ' '; ' _t _ ' '- ' -* * -

1PM has been described as a system of resource management that attempts to minimize the interaction between the pest and the management system through the integrated use of cultural, biological, physical and chemical controls. Implenientation of an IVM program utilizing modem ROW vegetation management techniques meets this definition completely; IVM is a system of resource (vegetation) management that minimizes interaction between the pest (tall growing trees) and the management- system (safe and reliable electric service) through the integrated use of cultural (mechanical and manual methods that Rhvsicallv remove tree stems), biological (low growing plants and herbivory), and chemical (herbicides) controls.

Utilities use three general routine procedures for removing tall growing trees from the ROW: (I) mechanical methods such as mowing with large machines and hand cutting with chainsaws, (2) chemical treatments, i.e., the selective application of herbicides and (3) combinations of both mechanical and chemical methods. -' : ' ' -

Mechanical methods of tree removal alone will clear the ROW of tree stems temporarily. However, employment of these mechanical methods allows trees to physiologically respond by regenerating quickly from the energy reserves contained in their undisturbed root systems. This tree regrowth occurs through such mechanisms'as "stump sprouting" and/or in some species "root suckering." This regenerative capacity i characteristic'of virtually all hardwoods, 3 e.g., maple, beech, birch,' aspen, oak, ash, cherry,'etc. ard is '

I ,Electric utility ROW arc strips of land, from 30 yards to over 300 yards in width, that are used by electric utilities as corridors for the transmission of electric energy.

2 The electrical facilities being discussed herein are for the most part high voltage transmissionlines and only those lower voltage distribution lines that have a discernible cleared ROW. There are more than 15,000 circuit miles of overhead transmission lines at or above 34.5kV belonging to the member systems of EEANY. ROW vegetation management under these electric transmission facilities is quite distinct from roadside tree trimming around distribution lines and these street tree-pruning operations are not the subject of this paper.

Hardwood is a conventional term for all deciduous (broad-leaved) trees belonging to the botanical class "Angiosperm."

Softwoods, also commonly referred to as evergreens and conifers, belong to the botanical class 'Gymnospermae" (and are practically confined to the order Coniferae") do not posses this regenerative trait (with one lone partial exception in the northeast - young pitch pine), and once cut below the lowest whorl of live branches will not resprout.

particularly pronounced in the juvenile or sapling stage of tree maturation resulting in the eventual production of many more stems than were originally cut. By drawing upon the food reserves in their undisturbed root systems and through a series of cbmplex compensatory physiological plant responses, the resurgent growth from the remaining portionsiof the tree (stump and/or roots) is actually enhanced when a tree stem is severed. It is through the production within the plant of naturally occurring stimulatory substances together with the loss of growth inhibitors (caused by the removal of the above ground growth centers) which then exert their influence on the remaining-vegetative structure to promote excessive new tree growth. These new, more numerous stems, growing much faster than when left uncut, (e.g., five to ten feet or more the first year after cutting) makes subsequent tree removal from the ROW more frequent, laborious, hazardous and costly.

The selective application of herbicides to only the tall growing target tree species can in most instances eliminate completely the resurgent tree growth problem because the herbicide when properly deposited on the target species translocates throughout the tree (including the root system) and arrests all future growth and development, i.e., killing the entire target plant not just temporarily removing the above ground portion.

Selective herbicide application involves two general techniques:4 a basal application to the lower stem of the tree and a foliar application to the leaves. Selective application of herbicides only to the targeted tall growing species allows retention of nearly all the desirable low growing vegetation on the ROW. The elimination of the tall growing trees from the ROW will also encourage the further growth and development of all the indigenous low growing woody shrubs, herbs (forbs and grasses), ferns, etc. by removing the trees that would otherwise begin to directly compete with and eventually "crowd out" the low growing species over time. With effective minimally disruptive tree removal, these lower growing desirable plant species will expand into the ROW areas formerly occupied by trees and produce a thick dense plant cover that will discourage the invasion of new tree seedlings and/or the future growth of any remaining tree seedlings. These desirable low growing plant communities act as the "biological controls" in this IPM/IVM scenario. The establishment and the preservation of these low growing plant communities on ROW serve to reduce over time the amount of work required and cost incurred by the utility to maintain the ROW each treatment cycle while coincidentally diminishing the amount of herbicide necessary for adequate coverage of the target species.

Mechanical and chemical controls are often used together with favorable synergistic results. For instance, a tree is manually cut with a chain saw and the resulting freshly severed stump is treated with a herbicide formulation to prevent resprouting. This procedure removes the immediate physical threat to the overhead electrical line as well as the future tree growth with little disruption to the surrounding desirable plant cover while requiring very limited use of herbicides in a highly efficacious spot application.

ESSENTIAL ELEMENTS OF AN IPM STRATEGY ILLUSTRA TIONS & EXAMPLES Traditional IPM programs consist of five basic elements: (I) preventive measures, (2) biological controls, (3) monitoring, (4) assessment, and (5) control measures. These essential elements of a sound IPlM1/IVM program are illustrated in the following examples.

1. Preventive Measures When the land uise of a ROW is altered to preclude the establishment and growth of trees, the utility has little, if any, ROW vegetation management activities to perform. This advantageous situation occurs when a ROW fee owner or adjacent land owner productively uses the ROW in a manner compatible with the electrical facilities, and this use usurps the potential development of tall growing trees. The most common ROW multiple uses often involve various types of agricultural 5 activities, i.e., crop production, pastures for grazing livestock, 4Many variations of these two techniques exist.

5It should be noted that most agricultural pursuits require the use of significant amounts of various pesticides, eg., insecticides, fungicides, herbicides, etc. on an annual basis. Thus, the total quantities of pesticide applications will often dramatically increase on those ROW areas converted to farmland as compared to the spot treatments of herbicides every four to seven years by the utility.

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and within certain height limitations even Christmas tree plantations and some types of orchards. 'Those agrarian activities, as well as many other types of allowable industrial, commercial and residential multiple uses; which effectively curtail the opportunity for aiy tall growing vegetation to becomfe established can thus eliminate completely the burden for'any ROW ve'getation management by the utility. However, any use of the ROW that allows even one tree capable of growing up into the electrical lines; e.g., hedgerows between cultivated fields, requires due diligence by the utility to prevent an'electrical discharge.'

2. Biological Controls

'One of the principle goals of ROW vegetation 'management is to promote low growing relatively stable (long lived) plant communities, which consisi of numerous species of woody shiubs, herbs (forbs and grasses),"

ferns, etc on the ROW.' These low growing plant communities are a very desirable ROW cceissory in that they inhibit both tree'establishment and their subsequent growth by directly competing withth6e tall growing species for the available site resources (sunlight, water, and nutrients). Thick low-growing plant communities, which hinder tree seed germination and the early development of the undesirable tree seedlings and small tree saplings, act as the biological control agents in this IPM/IVM strategy.'

'There may even be some indirect biochemical interactions, called allelopathy, occurring among various plants that result in a chemical competition of sorts between certain lower growing desirable ROW species and some of the tall growing tree species. Allelopathy has been defined as the influence of one plant on another via the production of natural growth inhibitors. Currently there exists only a limited understanding of this ability of plants to produce and release phytotoxic substances that can then be translocated to other plants and used to curtail certain critical physiological plant functions such as growth and reproduction. iThese naturally occurring "herbicides" offer yet another potential beneficial aspect of the biological controls in assisting the ROW vegetation manager to curb the spread of the undesirable tall growing trees.- -

In addition to their immediate benefits to the utility of reducing the undesirable tree population, these low growing plant communities offer an assemblage of plant species that provide diverse and productive habitat conditions for a wide variety of wildlife,'e.g;, birds and mammals. Managed ROW creates habitats that provide wildlife food and cover values that are remarkably different, and oftentimes surpassing, those of the neighboring forest. 'Also, this juxtaposition of two different, but complementary plant communities (one perpetually kept in a low growing condition and the other usually a forest) produces what is known as the "edge effect." This effect enhances wildlife profusion, i.e., abundance and diversity, in the boundary area transition zone (ecotone) between these two distinct habitat types. Some of the new and more numerous wildlife species attracted to these enhanced ROW created habitats provide yet another beneficial function of further reducing tree establishment and growth through their collective herbivory, e.g., browsing by deer and rabbits on young trees, girdling of tree seedlings by voles, and tree seed predation by mice.

3. ' Monitoring -

'As explicitly called for in an IPM program, monitoring of the pest population involves the following items: . :- .

- Regularly checking the area. - :

- Early detection of pests . - - ., .

-Proper identification of pests .. . - - .

- Noting the effectiveness of biological controls .

The ROW vegetation managers of the EEANY member systems routinely carry out all of these monitoring activities as an integral part of their electric utility ROW vegetation nmanagemfiit programs.

Monitoring prceduires have been integrated into the NYS Public Service Comm'ission approved "Loing Ternn ROW Management Plans' developed by each member system. Monitoring activities in'clude an evaluation of the previous treatments to determine overall program effectiveness as well as the current condition of the ROW so as to ascertain when the next treatment should occur and by what means. All of these procedures are part of a sound IPM1IVM strategy.- ROW throughout New York State are regularly inspected to determine the'height and density'of the tall growing-target tree species as well as the condition of the lower growing vegetation.

Inspection results help determine, to a large extent, the timing and type of ROW vegetation treatment that the utility implements.

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I These field inspections also serve another important function, i.e., the fulfillment of a quality7 assurance/quality control (QAIQC) program. This QA1QC component of the ROW.vegetation management program provides feedback as to the conduct of the field crews regarding their adherence to the work specifications as well as to determine the longer-term efficacy of the treatments. In addition to the routine utility monitoring, the Department of Public Service staff annually inspects the results of the company ROW vegetation management programs to insure compliance with all applicable regulatory mandates.

Identifying the undesirable tree species is a critical component of an IPM/IVM program. With hundreds of species present on a ROW, all vegetation treatment personnel must be sufficiently knowledgeable of plant species to enable them to readily distinguish between target trees to be treated, and all non-target desirable low-growing species to be left as undisturbed as possible. Based upon field inspections, the type of vegetation treatment will also be determined in large part by the distribution and abundance of the lower growing species.

For instance, when thickets of shrubs, such as viburnums or dogwoods, are present together with only a few target tree stems, the highly selective stem specific application of herbicides would produce the most acceptable results. The extensive use of mowing for example over such a ROW segment containing only a few target species would be quite disruptive to the existing desirable low growing vegetative cover. Such an ecological disturbance would unnecessarily leave the ROW in a much more open and vulnerable condition thereby actually enhancing the ROW site conditions for the eventual re-establishment of undesirable trees as well as significantly reduce its aesthetic and wildlife values.

4. Assessment Assessment is the process of determining the potential for pest populations (target trees) to reach an intolerable level. For ROW vegetation managers, the most opportune time to eradicate target trees is well before they reach the height of the overhead electrical lines. From an assessment perspective, an effective IPM/IVM strategy needs to: (a) prevent any interruption of electrical service and avoid risk of injury to the public, (b) treat the target species at their optimum height range as they emerge from the lower growing plant cover (at this stage they can be conveniently treated with limited amounts of herbicide so as to achieve the highest degree of control possible), (c) cause the removal of the target tree species before they become tall and dense enough to begin to crowd out and adversely alter the composition, structure and density of the desirable lower growing vegetative cover and (d) minimize any direct.disruption by the treatments themselves to the existing desirable ROW plants so they continue to occupy the ROW and function as biological controls.

5. Control Measures IPM strategy dictates that once a pest population has reached the intolerable level action should be taken. Typically, under an IPM program, chemical pesticides are used as a control measure when no other strategies will bring the pest population back under the economic threshold. In fact, the success of IPM often occurs by waiting until a pest population reaches this threshold and then often hinges on the availability of a pesticide to bring the pest population back under control quickly. For ROW vegetation management the pest population consists of only the target tree species that meet certain critical height6 characteristics. Only those trees that have emerged from the lower growing plant "canopy' need to be selectively removed; thus many very small tree seedlings may remain untreated, submerged within the low-growing plant community on the ROW.

Most of these small tree seedlings, left fully submerged within the dense low growing understory vegetation, will never fully develop into trees as they will succumb to the surrounding competitive pressures of the lower growing desirable vegetation and its associated biotic agents, e.g., animal herbivory. An additional positive attribute of this biological control feature occurs when those few remaining target trees that finally "escape" from

'This critical tree height' is determined electrically' by the distance between the tip of the tree and the overhead electric line with consideration for the voltage of the transmission facility, at any given point on the ROW. The higher the line voltage the more clearance that is necessary around the conductors which is oft referred to as the wire security zone. For instance, a 765 kV line requires a greater wire security zone distance (about 10 feet more) than a 345 kV line needs. Also, as the voltage of the transmission facility increases the minimum wire distance from the ground likewise increases. The minimum conductor sag at mid-span allowed for a 765 kV line is about 50 feet from the ground whereas a345 kV line only requires a height of around 30 feet from the ground. Finally, the location ofthe tree on the ROW will detemnine the distance to the conductors and the resulting allowable maximum tree height that can be tolerated at that particular point. Trees located near the edge of the ROW or close to tall towers can be allowed to grow taller than their compatriots located in the center portions of the ROW near conductor mid-span which is within the area of maximum line sag, i.e., where the line is closest to the ground.

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the low growing plant communities only do so after a considerably longer time period than would normally.

happen under relatively (open) unencumbered circumstances. This helps to extend the duration between ROW vegetation treatments.

The choice of treatment technique as well as the explicit mode of application to ensure adequate control of the target tree species are also important aspects of selective ROW vegetation management that uniquely qualifies IVM as an IPM approach.- As part of an IPM/IVM program, herbicides are used only to treat individual tree stems or groups of target trees, and no aerial or indiscriminate ground broadcast (blanket) applications (uniformly spraying the entire ROW) are used in New York State today. Herbicides that are used on ROW are matched to site-specific characteristics and target species, and the products are selected from dozens of commercially available materials based upon various attributes such as efficacy, toxicity, cost, etc: Furthermore, once a specific herbicide(s) is selected for application; its efficacy can be further enhanced (and its environmental impact minimized) by.proper timing and selection of the most suitable methodI(s) of treatment' (including integration with mechanical controls) together with choosing the most appropriate formulation and dosage rate.

'The option of non-chemical mechanical clearing of the ROW; by hand cutting with chainsaws, mowing with large machines like a hydro-ax or even using massive earth moving equipment in a stump/soil shearing operation, is most always an available alternative. These physical methods of tree species removal are used for those ROW segments occupied by or located close to sensitive land uses or containing special resources that have been determined to be vulnerable to the application of herbicides. These designated ROW locations can be granted this extra protection through the judicious use of"no spray zones" or 'set back distances" which are often referred to as "buffer zones".where herbicide use is not allowed. The determination not to use herbicides, can be made by the ROW manager on a site-specific basis or through general company policy even when law, regulation, and label conditions allow such herbicide use. The discretion to employ buffer zones as well as the selection' of the appropriate set back distances, must be made in a prudent manner since all the mechafiical alternatives will inevitably cause an increase in the number and vigor of incompatible tree species on those portions of the ROW so treated. However, the opportunity to employ mechanical clearing of the ROW is an available option for the ROW manager on specifically chosen ROW segments with certain predetermined characteristics that warrant this treatment. Herbicide usage can be restricted in deference to specific notable ROW resources or as a consideration to particularly sensitive land use conditions while still maintaining the overall goals of a sound, long term, and effective IVM program when viewed from a system-wide perspective.

Even in certain ecologically sensitive areas, the selective use of herbicides may be apropos provided the appropriate precautions are taken. For instance, when treating vegetation in or adjacent to designated wetlands, a herbicide with the appropriate characteristics, e.g. an aquatic or wetland label could be selected. However, to assure that virtually no surface water contamination occurs (irrespective of any allowable label statements) buffer zones can be prescribed around streams, lakes, wetlands, and other sensitive water resources. Studies have shown that buffer iones of only 5 to 25 feet can effectively curtail the deposition of airboriie'spray particles and the movement of the herbicide by runoff into'suifacce-water resources. A dense stand of'egetation in the buffer zone will further reduce the linear distanceof buffer zonre necessary, as will very stem specific tie'atment -

techniques. Conversely, sparse vegetation in'the buffer zone'and high volume treatmentsiwill increase the distance of the buffer zone required to insure-abateinent of any herbicide movement.' All established EEANY member system specifications for their buffer zones meet or exceed these threshold conditions.'

ROW CONVERSION One quite unique aspect of IPM, as applied to the management of ROW vegetation, is the relative long-term nature of the desired effects and the timefraine required to'assess the consequences of actions taken.

Although, mechanical removal of the tall growing trees will physically eliminate the immediate threat to' electrical reliability and public safety, this method only serves to perpetuate the long-term tree problem and exacerbate future ROW maintenance requirements. Typically, mechanical tree removal will result in the need for more cutting as frequently as every two or at mkist about four years. 'After'severail mechanical treatments, i.e.,

over a number of ROW treatment cycles, the collection of tree stems requiring control can readily increase to' over 20,000 stems per acre. Similarly, when a new ROW is cleared and all vegetation is allowed to grow back naturally,'the target tree densities will likewise increase to very high levels in only a few years after the initial' tree removal operations and prior to any herbicide'application. In fact the term "ROW Reclamation" is' 7

customarily used to describe the extreme actions that must often occur to treat very high tree stem densities that are frequently found on a routinely mechanically treated ROW.

When herbicides are used over several treatment cycles, the period of time between treatments can usually be elongated from three or four to six or seven or even more years and concurrently the number of stems to treat each cycle becomes fewer. Herein lies the truly unique aspect of ROW vegetation management from an IPM/IVM perspective; the treatment of vegetation with herbicides must be viewed over the long term to fully grasp the significance of this system in reducing the target tree population that will also reduce the use of chemicals and concurrently increase the effectiveness of the biological controls, i.e., all the lower growing plants that volunteer to occupy the ROW. For example, when a new ROW (or an older ROW that has received only mechanical treatments) is first treated the amount of herbicide needed for proper coverage of the numerous target trees may be in the order of about two to four gallons of concentrate per acre. The following treatment, in the next cycle, may require'about half that amount because the number of target species has been reduced and the lower growing desirable vegetation is beginning to exert it's influence on the ROW vegetation dynamics.

Subsequent treatments will continue this downward trend in herbicide usage that produces "nearly" a tree-free ROW requiring a minimum ofjudiciously applied herbicide to produce the desired effect. At this stage the low growing vegetation is firmly established and offers a relatively stable condition that effectively inhibits the rapid resurgence of trees. However, in order to'perpetuate this highly desirable minimum maintenance ROW condition, when new trees begin to emerge (as they most certainly will from the'tree seed sources off the ROW) these target trees must still be controlled through the diligent efforts of the ROW vegetation manager to preclude their fMll development and ultimate dominance over their lower growing associates.

This process of "conversion" from a ROW that is literally filled with trees to one that is dominated by lower growing vegetation with only a few remaining tree stems capable of growing into the overhead electric lines is not a simple one step process, but requires an extended program commitment and adherence to a long range vegetation management plan. Each phase in the ROW conversion process can be quite complex depending in large part upon the target species mix coupled with tree height and density together with the abundance and distribution of the low gro'wing vegetation as well as other site specific characteristics. As the stem density of the target species is reduced with each passing treatment cycle, the type of treatment chosen can then become more selective. Finally,' after several treatment cycles when the ROW is occupied by a low density of target trees and the conversion process virtually completed some continuing herbicide use will still be required, but the focus at this stage shifts to selecting techniques which offer the minimum amount of disturbance to the desirable lower growing vegetation, i.e., the biological controls.

GENERAL CONSIDERATIONS The use of herbicides by the EEANY member systems is subject to regulation under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) administered by the U.S. Environmental Protection Agency (EPA) and Article 33 of the New York Environmental Conservation Law (ECL) administered by the Department of Environmental Conservation (DEC). Pursuant to FIFRA regulations, no herbicide may be marketed, distributed, sold or advertised until the EPA registers it. After many years of product development, advanced toxicology studies and field testing, the pesticide manufacturers submit to EPA thousands of pages of research data that are compiled into a registration application. From this voluminous registration package, the manufacturer develops a proposed product label that identifies the pest or pests that the product will be effective in controlling and provides complete instructions for correct use, handling, and disposal of the product as well as other information required by FIFRA. In New York State, the DEC has the responsibility for establishing regulations and standards for the registration of pesticides, the certification of pesticides applicators, and all other matters pertaining to pesticide use as well as the responsibility for enforcement of all it's regulations and standards.

Other Federal, State and even local laws and their resulting regulations may impinge on the manner in which ROW vegetation management activities will occur. As mentioned previously, wetland protection requirements can have a pronounced effect on the types of vegetation management techniques chosen.

Considerations for the protection of endangered or threatened species and their habitats can similarly become a dominant concern on some ROW. For instance, the nurturing of the endangered Karner blue butterfly and its 8

requisite host plant, the blue lupine, has resuited in considerable evaluation of selected ROW herbicide use in the preservation and enhancement of the habitat conditions necessary for the survival of this endangered species of butterfly. Even the State requirements for management of river corridors under the Wild and Scenic Rivers Act provide definitions and requirements for IPM. Local ordinances, zoning mandates, as well as property owner concerns may sometimes play a critical role in the selection of ROW vegetation management techniques, e.g.,'

the control of poisonous plants, invasive weeds, and allergy producing pollinators. In some instances voluntary compliance with provisions of the Federal Noxious Weed Act may require action on the part of utility ROW vegetation managers to prevent the spread of listed deleterious weeds and other alien invasive species. For example, the control of infestations of the introduced weed, purple loosestrife, which threatens the biological integrity of North American wetland ecosystems by displacing native vegetation is a goal shared by the electric utility industry with both state and federal environmental agencies.

Prevention Of Non-point Sources of Pollution & Storm Water Discharge Requirements Another important regulatory program that can directly affect the choice of ROW vegetation management practices available under IPM/IVM is found within the authority of the Clean Water Act as amended by the Water Quality Act of 1987 and involves the control of non-point sources of water pollution along with some aspects ofthe'permit requiremenits for stormwater discharges for point sources resulting from construction activities: These iregulaiory programs focus on water quality issues, i.e., the prevention and control of water pollution.' In both programs, as they apply to the ROW maintenance situation, the focus is on using management practices to prevent, reduce, minimize or otherwise control the availability, release, or transport of substances that adversely affect surface and ground waters. They both act generally to diminish tie generation of potential water pollution emanating from sources on the ROW.

The control of non-point sources of pollution is accomplished through the identification of "best' management practices" (BMP's) and their implementation on a site-specific basis using best professional

judgment and experience. The control of stormwater discharges which can be considered as pointisources due to their collection of runoff into a single outlet, e.g., a culvert or ditch, are similarly treated by the requiremnenit to prepare a'"Stormwater Pollution Plan" under the auspices of a SPDES (State Pollutant Discharge.Elimination System) General Permit. 'This plan essentially enumerates the BMP's that will be used to'prevent and/or control polluted runoff from occurring. Neither of these programs imposes effluent limits-for specific s'bstncesrather they provide for an effective means of reducing or preventing the irpact of pollution generated fr'6m land '

management activities. In addition to the ROW managers primary concern of minimizing pesticide related impacts within the context of an IPM strategy, these two somewhat interrelated regulatory programs broaden the environmental concerns arising from IVM to enicompass other pollution control objectives. Thus, both of these clean water related programs could directly influence the decision-making process of the ROW vegetation manager and in some cases virtually dictate the menu of treatment choices available.

The most common potential source of pollution arising from a ROW is erosion and the resulting generation of sediment causing siltation in streams and other waterbodies. Sedimentation from all sources is a major water quality degradation issue in New York State. Also, the loss of soil nutrients and their entryway into surface watercourses or groundwater by-excessive leaching or as attached to'sediment particles is likewise an important water quality'concern. Both of these major sources of water pollution can be generated from ROW if bare soils are presenter insufficient plant cover occurs. --Therefore, in choosing ROW vegetation management techniques, particularly on steep slopes or other areas of high erosive potenitial, e.g., riparian zones, the ROW vegetation manager must be'concerned with their effects on the local hydrology. Vegetative disturbances.'

resulting'in bare'surfaces or exposed soils and the degree to which vehicular traffic miiovement occurs causing rutting can become limiting factors in the selecti6n of target tree control methods. -For instin'e, mowing with a hydro-ax on a steep slope or along a streambank could cause erosion by vehicular rutting as well as through denuding the site by excessive removal of vegetation.:

. ; , I. -,

The imposition of these regulatory programs to prevent and/or control sources of potential degradation of water resources arising from ROW vegetation management activities results in the following two general:

precepts: (1) maintain as complete a vegetative cover as possible at all times, and (2) keep exposed soil and any soil disturbance/compaction operations to a minimum especially in critical areas. By keeping these two relatively simple fundamental principles a host of positive attributes can be ascribed to the ROW vegetation management program including: (1) dense'low growing vegetation on the ROW will act as filter strips for the surrounding area thereby decreasing overland flow, increasing soil water percolation and removing pollutants, 9

(2) complete vegetative cover on the ROW will stabilize soils and prevent erosion and sediment transfer, (3) minimizing soil compaction by restricting heavy vehicular traffic on the ROW decreases the amount of surface water generated on a given area and thus reduces the volume of stormwater runoff, and (4) avoidance of any soil disturbance on the ROW will reduce or eliminate the need for amelioration activities that would otherwise be required under these clean water programs to restore the disturbed area to its original slope, soil compaction, ground cover, and hydrologic condition.

ROW Management Research IPM is never a finished or static process. As fresh data become accessible and new knowledge is obtained about the pests in question and the various control treatments available, the specifics and details of the currently acceptable IPM strategies will naturally be altered and thus subject to constant modification. IPM practitioners can aid and abet this dynamic adaptation and improvement process through conducting basic ecological research on the pests in question as well as applied research in new aid promising control strategies.

Also needed is the constant reappraisal of existing techniques in order to modify them to produce even more efficacious results. The member systems of the EEANY have individually conducted research into IPM related ROW management matters but even more so collectively, through the auspices of the former Empire State Electric Energy Research Corporation (ESEERCO) 7 , have collaborated on numerous research projects over a 25 year span of time involving many diverse aspects of ROW vegetation management. These studies were conducted on a wide range of subjects and a host of issues important to utility ROW managers in their execution of ecologically sound and cost effective IPM/IVM programs.

Beginning with a literature review in 1973, this extended ESEERCO ROW management research program has included projects on ROW treatment cost comparisons, long term effectiveness, ROW treatment cycles, herbicide fate and mobility, allelopathy, ROW multiple uses, buffer zones, soil compaction and mitigation, repeated mechanical cutting effects on vegetation and costs and the effects of ROW treatments on wildlife. Two of the more recent multi-year studies have recently been published in the mid 1990's; ROW Vegetatiori Dynamics conducted by the Institute of Ecosystem Studies and ROW Stability by the State University of New York College of Environmental Science and Forestry. The final ROW research product to come out of ESEERCO program in 2000 involves a risk assessment and environmental evaluation of the use of tree growth regulators. These numerous and diverse research projects have greatly assisted the New York State electric utility industry to focus their ROW Vegetation Management Programs on the most cost effective and least disruptive techniques while also allowing them to tailor the research results to their own individual company circumstances. The latest ROW research efforts currently being undertaken by the electric utility industry are now found within the bailiwick of the Electric Power Research Institute (EPRI). EPRI has picked up where ESEERCO left off and has created a new research target, "ROW Environmental Management &

Development" which is currently being subscribed to by 44 electric utilities across the nation.

Summary The overall goal of a utility ROW vegetation management program is to provide for the safe and reliable transmission of electric power in an economic and environmentally compatible manner. This lofty goal translates "on the ground" into the vegetative conversion of a strip of land, i.e., the ROW, often initially found filled with tree saplings to a ROW corridor that harbors mainly a profusion of lower growing species. This goal is currently being achieved in New York State by the implementation of sound IPM/IVM programs at each of the electric transmission and distribution systems of the EEANY members. To paraphrase applicable IPM terminology; ROW vegetation managers use multiple tactics to prevent pest (tree) buildups that could endanger electric system reliability and public safety by: monitoring pest (tree) populations, assessing the potential for damage (system reliability, public safety, preservation of the biological controls), and making professional management and control decisions, considering that all pesticides (herbicides) should be used judiciously. ROW management decisions depend in large part upon the mix of target species, the height and density of the dominate individual stems, and the abundance and distribution of the low growing desirable species. As the number of different target species is reduced and their stem density decreases with each passing treatment cycle, the type of vegetation treatment performed can become more selective with the attendant benefit of reducing the amount of XESEERCO ceased to exist in 1999 due to the increased economic pressures of a deregulated competiuive electric market 10

herbicide needed to maintain the ROW. Thus, after several treatment cycles, when the ROW is occupied bya greatly reduced number of target trees, some minimum herbicide use will still be required but the focus now' shifts to selecting techniques with the least amount of disturbance to the lower growing vegetation.

It should be stressed in closing that these ideal ROW conditions of a "minimn um 'maintenance"ROW'-'

(composed almost entirely of low growing plants) to be achieved through the attentive implementation of an' IPM/IVM program, is simply just that, minimum not zero maintenance. Although the low growing plants will help immensely in precluding the growth of trees,' due to the pressures of natural plant community succession i that ultimately will occur, (the close proximity to an abundant tree seed sources in the surrounding forest) these voluntary biological controls can never be expected to fully exclude trees alone over long periods of time from invading the ROW and exploiting their well defined ecological niches. Even after many treatment cycles using herbicides, when the ideal ROW condition is seemingly achieved, if the ROW is left untreated or if mechanical methods are resorted to, the ROW will revert rather quickly to a tree dominated landscape and all the attendant benefits of a stable low growing zilosaic of desirable ROW vegetation will be lost. These attendant benefits include species diversity in an aesthetically pleasing setting with increased wildlife abundance 'while piotecting soil and water quality values.' Thus IVM is truly an' ecologically based approach to pest management.

REFERENCES Abrahamson, Lawrence P., Ph.D., Christopher A. Nowak, Dr. Philip M. Charlton, Philip Snyder, Cost, Effectiveness of Herbicide and Non-Herbicide Vegetation Management Methods for Electric' Utility Rights-of-Way in the Northeast, Niagara Mohawk P Corporation Project JC28477AGP, prepared by Environmental Consultants, lnc.,Southampton, PA and The Research Foundation 6f the State University of New Albany, N.Y.,

December 1992' '

Canham, Charles D., Alan R. Berkowitz, Jay B. McAninch, Mark J. McDonnell, Richard Ostfeld, Vegetation Dynamics Along Utility Rights-of-Way: Factors Affecting the Ability of Shrub and Herbaceous Communities to Resist invasion by Trees, ESEERCO Research Report EP85-38, prepared by the Institute of Ecosystem Studies, Millbrook, N.Y. December 1993.

Cody, Jack B., John Quimby, Vegetation Management on UtilityRights-of-Way An Annotated Bibliography, prepared by State University of New York, College of Environmental Science and Forestry, Applied Forestry Research Institute, AFRI Research Report May 1975.

Edwards, David, Dr. Russell Jacoby, Dr. Edward McKyes, Marijean Remington, Spencer Thew, Everett Thomas, Soil Compaction:A ComprehensiveRetrospectiveLiterature Review, ESEERCO Research Report EP89-26, prepared by Atlantic Testing Laboratories, Limited., December 1990.

Edwards, David, Dr. Edward McKyes, Marijean B. Remington, Spencer F. Thew, Everet D. Thomas, Soil and Crop Response to PowerLine ConstructionTraffic andShallow and Deep Tillage in New York State, ESEERCO Research Project EP89-26, prepared Atlantic Testing Laboratories, Limited, March 1996.

ESEERCO Research Project, Environmental and Economic Aspects ofContemporaneousElectric Transmission Line Right-of-Way Management Techniques, Volume 1, General Methods, Special Studies, Discussion of Trends, and Conclusions, by Asplundh Environmental Services, Willow Grove, PA, June 1977.

Hadlock, Charles R., David E. Langseth, Herbicide Residue and Mobility Study: Existing and Simulation Model Review] Volume 4, ESEERCO Research Report EP84-8, prepared by Arthur D. Little, Inc., December 1987.

Hadlock, Charles R, David E. Langseth, HerbicideResidue andMobility Study: Existing and Simulation Model Review, Volume 11, ESEERCO Research Report EP84-8, p by Arthur D. Little, Inc., December 1987.

Johnston, Paul A, William C. Bramble, William R. Byrnes, Kenneth L. Carvell, David E. White, Harry V. Wiant, Long-Term Right-of- Way Effectiveness, ESEERCO Research Report EP83-15, prepared by Environmental Consultants, Inc., Southampton, PA, October 1985.

11

Johnston, Paul A., William C. Bramble, William R. Byrnes, Kenneth L. Carvell, David E. White, Harry V.

Wiant, Right-of-Way Treatment Cycles, ESEERCO Research prepared by Environmental Consultants, Inc.,

Southampton, PA, 1985.

Johnston, Paul A., William C. Bramble, William R. Bymes, Kenneth L. Carvell, David E. White, Harry V.

Wiant, Cost Comparisonof Right-of-Way Treatment Methods, ESEERCO Research Report EP80-5, prepared by Environmental Consultants, Inc., Fort Washington, PA, 1984 Kunzman, Mitchell R., Craig Stevens, Right-of-Way Chemical Treatments PhaseI - Site Preparation,.ESEERCO Research Project EP85-5, prepared by Tree Preservation Co., Inc. Briarcliff Manor, New York, October 1986.

Leopold, D.J.,J.R. Raynal, & G.S. Podniesinski. Vascular Species Richness and Rarity in Wetlands on Electric Power Rights-of-Way in New York State. ESEERCO Research Project EP91-6, prepared by SUNY College of Envrionmental Science and Forestry at Syracuse, New York. 1997 Norris, Logan A., Ph.D., Determination of the Effectiveness of Herbicide Buffer Zones in Protecting Water Quality on New York State Powerline Rights-Of-Way, ESEERCO Research Report EP89-44, prepared by Environmental Consultants, Inc., Southampton, PA, August 1991.

Schuler, Mark D., Paul a. Johnston, Dennis E. Holewinski, The Effects of Right-of- Way Vegetation Management on Wildlife Habitat, Gaps in the Literature, ESEERCO Research Report EP82-13, prepared by Asplundh Environmental Services, Willow Grove, PA. 1983 Wright, Daniel C. Ph.D., Development of Natural Growth Inhibitors for Overhead Transmission Rights-of-Way in New Y&rk State, Phase 1,Part A: Literature Review/Search/Update, ESEERCO Research Report EP90-14, prepared by Brooklyn Botanic Garden, Brooklyn, N.Y., July 1991.

12

APPENDIX 4 Page 1 of 41 Study Name: Vegetation management on utility rights-of-way.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy -.

Number: .. , -

.7 -Applied Forestry Research Institute, State University of New York, College of.,

PlslContractors: Environmental Science and Forestry, Syracuse, NY: -

Period: 1975 Cost: , - -;

Purpose and description: - i -

The objective of this study was to compile a list of annotated literature references for those interested in or working in utility right-of-way vegetation management and to provide a summary/synopsis of the state-of-the-knowledge on ROW vegetation management. This is the first ESEERCO report and served as the basis for selecting the direction of future experimental research.

Results:

The annotated bibliography contained 279 references and serves as one of the first comprehensive state-of-the-art literature reviews for vegetation management on utility ROWs. Approximately half of the references pertain to the use, effects, or safety of herbicides. The remainder of the references dealt with general ROW issues, vegetation management, methods and procedures of vegetation management, and wildlife benefits.

Cody (1975) concluded: Economic and environmentally acceptable maintenance of transmission line rights-of-way is a matter of great concern for power companies. While everyone agrees that some sort of vegetation management is necessary, there is a wide difference of opinion as to the most economic and environmentally acceptable method. After examining the literature, talking with many right-of-way managers and examining many rights-of-way, the following conclusions were reached:

1. Right-of-way vegetation management should start with initial clearing. Proper initial clearing can greatly reduce future maintenance costs and provide a more environmentally acceptable right-of-way.

2. While initial clearing is important, the greatest job confronting the right-of-way manager is maintenance of existing rights-of-way.

3. A great variety of conditions exists on rights-of-way requiring a variety of treatments to achieve desired results. The need for maintenance should be determined by line examination, and treatment should be prescribed according to species and conditions.

4. While mechanical methods of woody plant control are still needed and are being used, by far the most right-of-way treatment is done using chemical methods.

5. There are two general methods of applying chemicals: broadcast spraying and selective spraying.

While more acreage is probably being treated by broadcast methods at present (1975), selective methods are gaining rapidly.

6. Basal spraying is the most selective methods of chemical application, but other methods can also be used selectively; exceptions are helicopters, fixed boom sprayers and mounted mist blowers.

7. Preservation and development of stable low-ground cover is, in the long run, the most economical method of vegetation management It can be developed and maintained by selective spraying.

8. Where vegetation is dense, initial treatment by broadcast spraying may be the only practical way to reduce density and prepare the way for selective maintenance.

9. In remote areas or extremely rugged terrain, broadcast spraying by helicopter may be the only practical means of vegetation control. It may also be justified in certain other situations such as emergency conditions, shortage of labor, or where all, or nearly all, of the woody vegetation on a

Page 2 of 41 section of right-of-way is of an undesirable species.

10. Right-of-way maintenance success is highly dependent upon the preparation of good vegetation management plans, and reliable resources to carry them to completion.

References:

Cody, J.B. and J.R. Quimby. 1975. Vegetation management on utility rights-of-way: an annotated bibliography. Applied Forestry Research Institute, State University of New York, College of Environmental Science and Forestry, Syracuse, NY. AFRI research report no. 27.

Cody, J.B. 1975. Vegetation management on power line rights-of-way: a state of the knowledge report. Applied Forestry Research Institute, State University of New York, College of Environmental Science and Forestry, Syracuse, NY. AFRI research report no. 28.

Page 3 of 41 Environmental and economic aspects of contemporaneous electric Study Name: -- transmission line right-of-way management techniques.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy Number: ; ; -

PlI'slContractors: Asplundh Environmental Services, Willow Grove, PA Period: 1975-1976 Cost:

Purpose and description:

The purpose of this second study was to assess results of the state-of-the-art review as applied to New York by examining the 'record in the field'. By selecting a range of conditions from 22 ROWs across the state, an attempt was made to impute the cause-effect relationships between the past '

management techniques used and the observed conditions on the sites.: Results'could serve to improve ROW managers decisions in selecting and executing safe, eco'nomically and environmentally" compatible management programs.

Results:

Case histories of 22 rights-of-way managed using commonly accepted methods were carried out in:

New York State. Study sites were located in all nmajorforest regions of the state. Vegetation ' ' '

managernment over the previous decades on these ROWs fostered the'deelooment a complex of shrub-herb-grass communities. Shrubs found in adjacent forestst6 the ROW were prominent components of the ROW cover. Tree species continued to invade the ROW even with an established cove of shrubs, herbs, fems, and grasses. This pressure from invading trees, if left unmanaged, would re establish forest cover. Characteristic plant communities were developed in relation to habitat and were identified as: blackberry-goldenrod or suniac-goldenrod on mesic habitat areas; blueberry-sweetfem orblueberry-bracken fern on xeric areas; and willow-sensitive femri, red-bsier dogwood-sensitive fern or spirea-sensitive fern on hydric areas. ROW management has improved Wildlife food and cover conditions and plant species diversity. Species diversity was conisistently higher on the ROWs than in adjacent forests. Impacts of ROW management on erosion arid stream water were negligible; construction disturbances were the exception. Generally, there was little change in adjacent land use to the ROWs since ROW construction.

References:

Asplundh Environmental Services. 1977. Environmiental and economic aspects 6f coriternmporaneous electric transmission line right-of-way management techniques, Volume 1: General methods, special studies, discussion of trends, and conclusions. Empire State Electric Energy Research' Corporation. 209 p.Vol. 1 of 3.

Asplundh Environmental Services. 1977. Environmental and economic aspects of contemporaneous electric transmission line right-of-way management techniques, Volume 2: Individual case studies of sites 1through 11. Empire State Electric Energy Research Corporation. Vol. 2 of 3.'

Asplundh Environmental Services. 1977. Environmental and economic aspects of contemporaneous electric transmission line right-of-way management techniques, Volume 3:lndividual case studies of sites 12 through 22. Empire State Electric Energy Research Corporation. Vol. 3 of 3.

Page 4 of 41 Study Name: Cost comparison of right-of-way treatment methods.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy EP 80-5 Number:

KT. McLoughlin, New York Power PooVESEERCO; Pi'slContractors: Environmental Consultants Inc., Fort Washington, Pennsylvania.

Period: 1980-1984 Cost: $1,202,638 Purpose and description:

The objective of the study was to compare effectiveness and cost per acre of seven ROW treatment methods. Treatment methods of hand cutting, mowing, cut stump, dormant basal, summer basal, selective ground foliar, and aerial were applied to 18 ROW segments. 2,4-D+picloram and triclopyr herbicides were utilized. Effects of treatment type on the density of capable species were analyzed. A cost comparison of the seven methods was conducted.

Results:

The effect of seven treatment methods-hand cutting, mowing, cut stump, dormant basal, summer basal, selective ground foliar, and aerial-on capable tree densities varied. In the high density class all treatments decreased density. Medium density class increases were observed in segments treated with hand cutting, mowing, and cut stump methods. Mechanical treatments produced stem reductions.

of <60% at all densities. Cut stump was most effective at high densities. Dormant basal, summer basal,- and aerial treatments exceeded 60% stem reduction at medium and high densities but only summer basal was as effective at low density. Selective ground foliar reductions were 71%, 100% and 59% at high, medium, and low densities, respectively. All treatments produced >60% reduction in mean height on both high and low height sites. Based on a single application of treatments, hand cutting, cut stump, and mowing were less expensive than basal spray treatments ranging from $91-

$159, $113-$309, and $162-$193, respectively, depending on stem density. No highly adverse impacts on wildlife habitat were caused by any of the ROW treatments. Cost and effectiveness comparisons of girdling, frilling, basal injection, and stem injection found girdling to be the least desirable method

References:

Environmental Consultants, Inc. 2000. Cost comparison of right-of-way treatment methods: Update 2000. C.A. Nowak, B.D. Ballard, P.M. Chariton (comps.). Electric Power Research Institute, Palo Alto, CA, and Empire State Electric Energy Research Corporation, Schenectady, NY. EPRI Report No. 1000270.

Environmental Consultants Inc. 1984. Cost comparison of right-of-way treatment methods. Empire State Electric Energy Research Corporation, Schenectady, NY. Research Report EP 82-13.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature.- C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

Page 5 of 41 Study Name: The effects of right-of-way vegetation management on wildlife habitat.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy EP 82-13 Number: .2,- ,

K.T. McLoughiin, NewYorkPowerPool/ESEERCO;.

Pi's/Contractors: Asplundh Environmental Services, Will Grove, Pennsylvania.

Period: 1982-1983 Cost: $23,759 Purpose and description:

The objective'of this project was to summarize the knowledge of the effects of standard ROW vegetation management practices on various wildlife species and their attendant habitats in New York State. The supporting objectives of this project were to: (1) conduct a review of pertinent literature, (2) identify ongoing related research, (3) identify both positive and negative impacts on wildlife habitats, and (4) determine gaps in the knowledge.'

This project examined the available'data combining it with expert analysis and opinion in order to make predictions about consequences of alternative management actions. This was accomplished by conducting a thorough state-of-the-art literature' review including a summary of ongoing research and*

a survey of unpublished data. - -

Results: ..-

Initial impacts of ROW vegetation management are usually less favorable to wildlife than the long-term impacts. Treatments performed upon ROWs with high tree densities resulted in an immediate reduction in food and cover available to wildlife, whereas selective treatments on ROWs with a low or medium density of trees resulted in minimum reductions. Successfully managed ROWs that develop relatively stable shrub/herb/grassland plant communities benefit a wide variety of wildlife species.

Vegetations management on ROWs encourages a broad spectrum of wildlife species, though the habitat requirements of all species cannot be met, thereby discouraging some species.

References:

Asplundh Environmental Services. 1983. The effects of right-of-way vegetation management on wildlife habitat. Empire State Electric Energy Research Corporation, Schenectady, NY. Research Report EP 82-13. ! v .

Summary compiled from: . -I:

^.

McLoughlin, K. T. 1991. Right-of-way vegetation management in New York State. In: Workshop Proceedings: Herbicides and Right-of-Way Management Regulations, Use, Toxicology, Risks, Impacts, and Alternatives, November, 1991, Albany, New York. Niagara Mohawk Power Corporation, Syracuse, New York.: -

Page 6 of 41 Study Name: ROW multiple uses.

Study Sponsor. Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy EP 82-14 Number:

Pi's/Contractos: KT.McLoughlin, New York Power PooVESEERCO; nKane & Carruth, P.C., Pleasantville, New York.

Period: 1982-1983 Cost: $113,374 Purpose and description:

Demands for other uses of electric transmission line rights-of-way (ROWs) have increased as the availability of open land has declined. These ROW lands are attractive to both the underlying fee owner or adjacent property' as an extension of their existing preferred land use. Additionally, powerline corridors offer opportunities for recreational pursuits by segments of the general public. Unfortunately these varied and often conflicting uses have resulted in increased maintenance costs, security concerns, and public relation problems for the utility companies. The purpose of this project was to gather all available information on multiple uses of transmission ROWs into a summary report on the management and administration of these multiple uses. This project was conducted by the following sequence of items: review of the literature; a survey (written questionnaire with follow-up interviews) of ESEERCO member system personnel involved with transmission line ROW management; determination of the relative adverse impacts as well as benefits to ROW maintenance costs due to both authorized/desirable uses as well as the unauthorized/undesirable uses; and an examination of the legal implications of ROW multiple use particularly the liability to the utility.

Results:

The final report summarized all available literature on ROW multiple uses and included an annotated bibliography. A summary of survey responses was also presented. Analysis of this information provided summaries on such topics as utility multiple use policies, compatibility of uses, management strategies to control incompatible'uses, accommodations of complaints, risk assessment, legal implications, management prerogatives to encourage compatible uses, compatibility criteria, and the current management of multiple use by the ESEERCO member systems as well as regulatory perspectives on these issues.

References:

Kane & Carruth, P.C. 1983. The state-of-the-art of the management of multiple uses of electric transmission line rights-of-way. Empire State Electric Energy Research Corporation, Schenectady, NY. Research Report EP 82-14.

Summary compiled from:..

McLoughlin, K T. 1991. Right-of-way vegetation management in New York State. In: Workshop Proceedings: Herbicides and Right-of-Way Management Regulations, Use, Toxicology, Risks, Impacts, and Alternatives, November, 1991, Albany, New York. Niagara Mohawk Power Corporation, Syracuse, New York.

Page 7 of 41 Study Name: Long-term right-of-way effectiveness.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project Name/Study EP 83-15 Number:

KT. McLoughlin, New York Power PooVESEERCO; Pl'slContractors: P.A. Johnston, Environmental Consultants Inc., Fort Washington, Pennsylvania.

Period: 1983-1985 Cost: $145,000 Purpose and description: -

The objective of the study was to compare effectiveness of seven vegetation maintenance treatments."

Vegetation maintenance methods-hand cutting, mowing, cut stump, dormant basal, summer basal, aerial, and selective gr6und foliar.-were evaluated on effectiveness to reduce stem density on, treatment plots along ROWs. Tordon and Garfon herbicides were utilized.

Results: - * ;

Based on three density classes, high, medium, and low, a comparison of effectiveness of seven ROW treatments-hand cutting, mowing, cut stump, dormant basal, summer basal, aerial, and selective ground foliar-on undesirable plants (trees) was performed. Hand cutting was followed by an increase for all density classes. Mowing was followed by 44, 13, and 29% decreases in the three classes, respectively. Cut stump showed 71,-48, 'and 8% decreases, dormant basal was followed by 75, 57, -

and 63% reductions for each class, summer basal had 76, 83, and 57% reductions, selective ground foliar showed 81; 67, and 41% density decreases, and aerial treatment was followed by 81,74,'and 68% decreases in stem density for the three classes; respectively. A correlation of treatment effectiveness and initial stem density,- the relationship of the height of capable trees to the effectiveness of the treatments,'and the effectiveness of treatments on common capable tree species is also discussed.

References:

Environmental Consultants, Inc. 2000. Long-term right-of-way effectiveness: Update 2000. C.A -

Nowak, B.D. Ballard, P.M. Chariton (comps.), Electric Power Research Institute, Palo Alto, CA, and Empire State Electric Energy Research Corporation, Schenectady, NY. EPRI Report No.

1000271.

Environmental Consultants Inc. 1985. Long-term right-of-way effectiveness. Empire State Electric Energy Research Corporation, Schenectady, NY. Research Report EP 83-15. -

Summary compiled from: ' ' -' ' .

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-0110096..

. ~

I . ~~~I

. ~ .:.I1, ..

Page 8 of 41 Study Name: Right-of-way treatment cycles.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project Name/Study EP 84-26 Number:

Pi'sContractors: - KT. McLoughlin, New York Power PooVESEERCO; P.A. Johnston, Environmental Consultants Inc., Southampton, Pennsylvania.

Period: 1980-1985 (data)

Cost: $226,597 Purpose and description:

The study objectives included the evaluation of the cost and effectiveness of ROW treatment methods. Seven ROW treatments-hand cutting, mowing, cut stump, dormant basal, summer basal, selective ground foliar, and aerial--were evaluated for cost and effectiveness. The study specifically determined long-term costs, cycle length, density and height of capable trees, changes in desirable non-target vegetation, and the average annual cost among treatment types. This is the third study in a six-year project, which began in 1980 with the collection of baseline data. ROW treatments were applied in 1981, and initial effectiveness data were collected in 1982 (EP 80-5). Longer-term effectiveness was evaluated in 1983 (EP 83-15), and data for this study were collected in 1984 and 1985.

Results:

Fifty-four percent of the study sites treated using seven treatment methods-hand cutting, mowing, cut stump, dormant basal, summer basal, selective ground foliar, and aerial-had a 3 yr treatment cycle, 24% had a 4 yr cycle, 18% had a 5 yr cycle, and 4% had a 6 yr cycle. For sites with a 3 yr cycle, hand cutting showed an increase in stem density by 14%. Summer basal showed the greatest density change with a 76% reduction. At the end of the treatment cycles, ROW sites treated with summer basal had the greatest reduction in density and the lowest density of all the treatment types.

All other treatments reduced density except hand cutting, which showed an increase and had the highest average density of all treatment types. The average capable height was effectively the same at the time of retreatment regardless of which treatment was used. Cut stump had the greatest reduction in capable species height while selective ground foliar showed the greatest increase in capable species height Total shrub cover increased following all treatments, with selective ground foliar and dormant basal showing the best results. Aerial treated sites showed the greatest increase in herbaceous plant cover, while summer basal showed the least

References:

Environmental Consultants, Inc. 2000. Right-of-way treatment cycles: Update 2000. C.A. Nowak, B.D.

Ballard, P.M. Chariton (comps.), Electric Power Research Institute, Palo Alto, CA, and Empire State Electric Energy Research Corporation, Schenectady, NY. EPRI Report No. 1000525.

Environmental Consultants Inc. 1985. Right-of-way treatment cycles. Empire State Electric Energy Research Corporation, Schenectady, NY. Research Report EP 84-26.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

Page 9 of 41 Study Name: ROW effects from herbicide residues.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy EP 84-8 Number:

Pl'slContractors: K.T.' McLoughlin, New York Power PooVESEERCO; D.E. Langseth, A.D. Little, Inc., Cambridge, Massachusetts.

Period: 1984-1988 Cost: $249,000 Purpose and description: ,.

To develop methods to determine and predict the environmental fate, i.e., migration, distribution and persistence of herbicides as they are applied to electric transmission line RO\s in New York State.

The primary emphasis was the characterization of the environmental pathways and rates of degradation of herbicide applications as practiced in NYS. A secondary objective was the establishment of an informative base for responding to public concerns with off site vegetation damage, potential threats to water quality and other perceived adverse effects of herbicide application. The third and final objective was the creation of a future research plan to conduct field and laboratory studies.'

The study integrated a literature review with an evaluation of existing applicable fate models. ;The -

models selected were then run using parameters typical of NYS conditions. Model results were then compared to measured values cited in the literature.- Herbicides reviewed in the literature include, dicamba, fosamine amrmonium, glyphosate, 2,4-D, picloram, triclopyr, dichlorprop, and AMS. The model was evaluated for 2,4-D, picloram, and triclopyr under two typical NY ROW conditions.

Results: - - - -

The primary parameters which characterize potential herbicide behavior in the terrestrial environment are the soil adsorption coefficient, aqueous solubility, vapor pressure,'degradation rate in soil, and -

dissipation rate from leaf surfaces. The simulations/modeling approaches were determined to be '

suitable for predicting herbicide mobility'and residues consistent with observed field studies reported in the literature. - -

References:

A.D. Little, Inc. 1987. Herbicide residue and mobility study: Existing data and simulation model review.

Empire State Electric Energy' Research Corporation, Schenectady, NY. Research Report EP 82-

.13. - - - - - .

Summary compiled from: . . . ..-

McLoughlin, K T. 1991. Right-of-way vegetatiori management in New York State:. In: Workshop Proceedings: Herbicides and Right-of-Way Management Regulation s, Use, Toxicology, Risks, Impacts, and Altematives, November, 1991, Albany, New York. Niagara Mohawk Power' Corporation, Syracuse, New York.

U Page 10 of 41 Study Name: Herbicide mobility study.

Study Sponsor: Niagara Mohawk Power Corporation Project NamelStudy Volney-Marcy research project Pl's/Contractors: Calocerinos & Spina Consulting Engineers, Liverpool, New York Period: 1985 Cost:

Purpose and description:

A study was conducted at the Niagara Mohawk Power Corporation's Volney-Marcy transmission line right-of-way to determine the degree of mobility and persistence of herbicides applied to the site.,

Applications of herbicides were made by basal, foliar, and boom spray techniques. The plots consisted of abandoned agricultural, woodland, and grub sites. Soil and water samples were collected at the site before herbicide application, and at several time intervals afterward. The samples were analyzed for the herbicides which had been applied: triclopyr, picloram, and 2,4 D.

Results:

Overland flow of herbicides in runoff did not occur under normal conditions, but two off ROW soil samples did contain detectable levels of herbicide. In both instances, the herbicide application was immediately followed by rainfall. The linear extent of overland flow was minimal, and when it occurred, the herbicide degraded rapidly. After the initial application, there was no indication that overland migration of herbicide off the site was occurring. Rather, the trend was towards degradation of herbicides to undetectable levels. Entry into streams from overland flow is highly unlikely when appropriate non-treatmnent buffer zones are established adjacent to water resources, as is entry into wells or groundwater through leaching. Leaching to a depth of 10-15 inches of herbicides on the sprayed sites was rare, occurring only at three locations. The leaching likely occurred under three types of circumstances: (1) rainfall immediately after application, (2) a large amount of rainfall within a day after application, and (3) the basal application of a high concentration of herbicides to a single spot on the site. Herbicide concentrations in seepage from the top 6 inches of soil followed similar trends in mobility and persistence in soil samples. Drift of herbicides off the treated right-of-way did not occur during the study, because non-volatile herbicides were used and were carefully applied using proper techniques.

During the study, the herbicide 2,4-D did not persist past four weeks; Picloram did not persist past ten weeks: Triclopyr applied by the foliar method in a water carrier did not persist past ten weeks.

Triclopyr applied by the basal method in an oil carrier persisted up to 18 weeks. This unusual length of persistence likely resulted from the high initial herbicide concentrations in localized spots associated with the application method. Because the herbicides biodegrade rapidly, the possibility of movement of the material into adjacent water resources is greatly diminished, especially when proper buffer zones are established.

Reference:

Calocerinos & Spina Consulting Engineers. 1985. Herbicide mobility study. Niagara Mohawk Power Corporation, Syracuse, NY. NMPC final report.

Page 11 of 41 Study Name-: Right-of-way Ep r . chemical .. .e . . C rpreparation.

.E .e t ,C.Etreatments-site r a. o E. E R Study Sponsor Em'pire State Electric Energy Res'ear'ch'Corpora'bon (ESEERCO)-

Project NamelStudy EP 85-5 I: . I.. -:

Number:

- K.T. McLoughlin, New York Power PooUESEERCO;.

Pi's/Contractors: C.H. Stevens, Tree Preservation Company, Inc., Briarcliff, New York Period: 1985-1987 Cost: $61,224 Purpose and description:

The overall objective of this two-phase study was to determine the effectiveness of 25 different chemical treatments. This first phase of the project was designed to prepare the selected ROW segments, using handcutting, for future application of a variety of herbicide types, formulations and treatment methods to establish a comparative efficacy test. The chosen ROW segments were studied for previous ESEERCO projects (EP 80-5, 83-15, 84-26) and were found to contain the ideal species composition and density characteristics for this study. However, due to the resulting regrowth from l having been mechanically cut previously (1981), the wire security zone was in danger of being breached. Therefore, in order to use these sites for the future chemical treatments, additional handcutting was required to reduce the growth to a uniform lower condition. This provided a unique opportunity to gather'additional data on the costs of handcutting. In determining handcutting costs the" additional cost of slash disposal (hand piling and mechanical raking of the slash) was also determined. - - - --

Results:

Site preparation using handcutting resulted in an average treatment time of about 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per acre for all 30 units. The averages of manhours based on vegetation density were: 6.2 (high), 3.1 (medium) 1.8 (low) . For vegetation in the high density category, the average handcutting times based upon topography were 7.4 (steep), 6.5 (sloped), 5.8 (level). The average manhours per acre for all hand disposal units was 5.3. Averages of hand disposal manhours based upon vegetation density were 9.8 (high); 3.9 (medium) and 1.2 (low). The average hand disposal times on high density units based-_ -

upon topography differences were 13.4 (steep), 9.5 (sloped) and 3.3 (level). The average machine.

disposal manhours was only 1.8 per acre but significant equipment costs were also incurred for this technique. -

References:

Tree Preservatiorn Company, Inc. 1987. Right-of-waj chemical treatments--site preparation. Empire State Electric Energy Research Corporation, Schenectady, NY. Research Report EP 85-5.

Summary compiled from: " :

McLoughlin, K T. 1991. Right-of-way vegetation mnanagrement in New York State. In: Workshop' Proceedings: Herbicides and Right-of-Way Management Regulations, Use, Toxicology, Risks, '

Impacts, and Altematives, November, 1991, Albany, New York. Niagara Mohawk Power Corporation, Syracuse, New York.' --

- s Page 12 of 41 Project Name: ROW vegetation dynamics.

Stud Sonsor Empire'State Electric Energy Research Corporation (ESEERCO) and uy Sp Central Hudson Gas & Electric Corporation Project Name/Study EP 85-38 Number:

C.D. Canham, Institute of Ecosystem Studies (IES), Cary Arboretum, PlslContractors: Millbrook, New York.

Period: 1985-1991 Cost: $1,462,518 total Purpose and description:

The purpose of this series'of studies was to conduct basic ecological research on vegetation dynamics along rights-of-way, with specific emphasis on understanding the processes that inhibited invasion of communities dominated by shrub or herbaceous species by trees. The objective was to contribute to the body of ecological science that is needed to maximize the effectiveness of ecologically-based management of utility ROWs. Fifteen studies were conducted in the following general categories:' patterns and dynamics of ROW vegetation, dynamics of tree seeds and seedlings, competition, and herbivory.

Results:

Summary of fifteen studies compiled fromInstitute of Ecosystem Studies (1993, p. 341-353):

ROW vegetation is often extremely diverse, and is an important component of overall landscape diversity, particularly in heavily forested landscapes. ROW vegetation is commonly Opatchy, producing mosaics of small communities that differ in composition, structure and dynamics. On undisturbed ROWs, shrub cover is increasing, particularly for gray dogwood on moist sites; Gray dogwood appears capable of establishing and maintaining long-term dominance of a site if invading trees are systematically and selectively removed.,

Tree invasion is directly proportional to the number of seeds dispersed into a site, and resistance by shrubs does not appear to be density dependent, though seed predation may be. Sapling emergence will vary significantly from year to year and site to site due to pulses in seed production; cohorts of seedlings will emerge 10-40 years after such a pulse. Most new tree invasion along ROWs in the Hudson Valley comes from large-seeded, wind-dispersed species (i.e., maples and ashes), and secondarily from large-seeded, animal dispersed species (i.e., oaks). Light-seeded, widely dispersed,

.pioneer tree species appear to be effectively inhibited by intact ROW vegetation. Dormant tree seeds buried in the soil are not an important source of seedlings for any of the common trees invading ROWs in the Hudson Valley. The adjacent forest community has a significant effect on the species and the rate of trees invading the ROW. On ROWs wider than 30 meters (100 ft.) that are bordered by forests, rates of tree invasion will be highest adjacent to the edges and drop off at distances greater than 15 meters from the forest edge.

Natural mortality reduces tree density throughout the process of invasion-from the time of arrival of seeds to sapling emergence. Tree invasion is not limited to disturbances within ROW vegetation. Tree seedlings exploit natural variability in resource availability within ROW vegetation. However, the heterogeneity perse does not appear to be an important determinant of overall rates of invasion (i.e.,

successful invasion on favorable microsites is offset by poor survival of tree seedlings in unfavorable microsites). Tree seedling density is not necessarily a good predictor of the number of seedlings that will survive to sapling size because the factors that determine seedling establishment often appear to be inversely related to the factors that determine subsequent survival. Rates of tree invasion are highly sensitive to small changes in growth and mortality of older seedlings (i.e., small differences among communities in annual rates of growth and survival of older seedlings have a significant effect on overall rates of invasion).

The net competitive effects of low-growing communities on tree seedling growth and survival are the

Page 13 of 41 result of the combination of (1)the effects of low growing communities on the availability of resources essential for seedling growth; and (2)the responses of tree seedlings to variation in re'source availability. There are fundamental differences in the degree to which the specific resources (light, moisture and nutrients) required for tree seedling growth can be depleted by low-growing -

communities. Low-growing communities differ significantly in the amount of shade they cast There was little evidence that the communities differ in the'degree to which they deplete the availability of.

water. There is considerable variation among the low-growing communities in the supply of nitrogen (from the decomposition of organic matter in the soil):.The effects of ROW vegetation on tree seedling growth and survival can be both positive ("facilitation") and negative ("inhibition"); the net effect will depend on the balance over the period from seedling establishment to sapling emergence, but will vary depending on the physiology and ecology of individual tree species (e.g., shade tolerant versus shade intolerant species).

The intensity of competition between ROW vegetation and tree seedlings varies directly with site quality. The net negative effect of ROW vegetation on seedling growth is greatest on productive soils.

On physically.stressful sites, seedlings grow slowly even in the absence of intact vegetation. As a result, competition and physical stress tend to balance one another, resulting in relatively low growth rates for newly established seedlings, regardless of community type or site quality. One implication of this result is that disturbance to the intact vegetation will be particularly detrimental on productive sites, where seedlings can rapidly exploit any openings. In contrast, poor quality sites may be less sensitive to short-term disturbance because physical stress severely limits early seedling growth and survival of most species even in temporary openings in ROW vegetation. Thus, the duration of, competition (i.e. the number of years it takes for a seedling to overtop the ROW vegetation) is more important to tree invasion than the intensity in any given year (e.g., shrub cover can depress seedling growth longer than herbaceous communities). ROW vegetation inhibits tree seedling growth through competition both aboveground (for light) and belowground (for water or nutrients), Most low-fgrowing communities on most sites inhibit tree seedling growth through simultaneous limitation of the availability of both light and soil resources. Aboveground competition will often be the predominant interaction on productive sites, while belowground commpetition is greatest on more stressful sites. This reinforces the conclusion that productive sites will be'the 'iiost sensitive to disturbance't6 the caho`py of ROW v'egetation. '

Seed predation, primarily by white-footed mice, isfrequently an important source of mortality for seeds that are dispersed inito rights-of-way. 'Short-term rates of seed predation are higher under shrubs than in herbaceoUs-dbriinated communities, pre7iimably reflecting the habitat preferences of white-footed mice. Seedling predation (outright mortality of seedlings due to consumption), primarily by meadow voles, is a potential major source of mortality for tree seedlings.

Rates of seedling predation are greatest when meadow vole population densities are high; but significant predation occurs even at low vole population densities. Seedling predation by meadow voles may be restricted to herbaceous communities that provide suitable habitat. Therefore, the relative importance of seed predation versus seedling predation may vary significantly as a function of the amount of woody cover within a site. Mammalian browsing on tree seedlings, by both white-tailed deer and eastern cottontail rabbits, significantly reduces the rate of tree invasion in most ROW communities. Deer browsing within rights-of-way is highest in heavily forested landscapes. Browsing rates are highest on seedlings that are not overtopped by adjacent shrubs or herbaceous species.

The effects of browsing on seedling growth and mortality depend strongly on the timing and intensity of browsing, and the levels of other stresses experienced by a seedling. Even heavy winter browsing of unshaded seedlings for 2 successive years has little effect on either growth or survival of tree seedlings. Whereas summer browsing has significant effects on seedling growth and survival.

Overall rates of tree invasion in any given community reflect the net results of a large number of processes (i.e. seed dispersal, seedling establishment, first-year seedling survival, etc.) Shrub communities had the highest resistance to tree invasion of the communities examined in our research, though long-term ability of the community to resist tree invasion was not evaluated during the relatively short life of this project. Herbaceous communities on poor soils (specifically, little bluestem meadows) also had high net resistance to tree invasion. The communities with the lowest resistance

Page 14 of 41 to invasion were herbaceous communities on productive soils. These herbaceous communities on good soils often represent very early stages of old field succession, and are undergoing rapid colonization by shrubs.

References:

Berkowitz, A. R. and C:D. Canham.1995. Ecological perspectives on tree invasion in rights-of-way:

New competitive effects of intact vegetation. p. 54-58 In G.J. Doucet, C. Seguin, and M. Giguere (eds.) Proceedings of the 5t International Symposium on Environmental Concerns in Rights-of-Way Management, September 19-22, 1993, Montreal, Quebec, Canada.

Berkowitz, A.R., C.D. Canham, and V.R. Kelly. 1995. Competition vs. facilitation of tree seedling growth and survival in early successional communities. Ecology 76(4):1156-1168.

Boeken, B. and C. D. Canham. 1995. Biotic and abiotic control of the dynamics of gray dogwood (Comus racemosa Lam.) shrub thickets. Journal of Ecology 83:569-580.

Canham, C. D., J. D. Hill, A. R. Berkowitz, and R. S. Ostfeld. 1995. Ecological perspectives on tree invasion in rights-of-way: quantifying variation'among communities in resistance to tree invasion.

p. 81-86 In G.J.' Doucet, C. Seguin, and M. Giguere (eds.) Proceedings of the 5h International Symposium on Environmental Concerns in Rights-of-Way Management, September 19-22, 1993, Montreal, Quebec, Canada.

Dickinson, Matthew B., Francis E. Putz, and Charles D. Canham. 1993. Canopy gap closure of the clonal shrub, Comus racemosa. Bulletin of the Torrey Botanical Club 120(4):439-444.

Hill, J.D., C.D. Canham, and D.M. Wood. 1995. Pattems and causes of resistance to tree invasion in rights-of-way. Ecological Applications 5(2):459470..

Institute of Ecosystem Studies. 1993. Vegetation dynamics along utility rights-of-way: Factors affecting the ability of shrub and herbaceous comrmiunities to resist invasion by trees. C.D.

Canham (ed.). Empire State Electric Energy Research Corporation, Altamont, NY. Final technical report EP 85-38.

Putz, F.E. and C.D. Canham. 1992. Mechanisms.of arrested succession in shrublands: root and shoot competition between shrubs and tree seedlings. Forest Ecology and Management 49:267-275.

Page 15 of 41 Study Name: Tree growth retardants.

Study Sponsor: Empire'State Electric Energy Research Corporation (ESEERCO)

Project Name/Study E 82 Number Number Y EP 88-29 PI'slContractors: K.T. McLoughlin, New York-Power Pool/ESEERCO;

'ACRT, Inc.

Period: 1988-1990 Cost:

Purpose and description:

The objective of this study was to evaluate tree growth regulator (TGR) usage within the utility industry. The project consisted of three parts- (1) an annotated bibliograp hy of treelplantgrowth -

regulator information, (2) a search of unpublished literature and mail-phone surveys,' and (3) a workshop to determine future research dire'ction and usage recormmendations of TGRs by New York State utilities.

Results: -

Six TGRs were identified as the major compounds that have been used in utility situations, including maleic hydrazide (Slow Grow), dikegulac sodium (Atrinal), chlorflurenol (CF125 or Maintain A),

paclobutrazol (Clipper), flurprimidol (Cutless), and uniconazole (Prunit). Dikegulac, maleic hydrazide, and chlorflurenol affect cell division and block apical dominance, restricting terminal growth.

Paclobutrazol, flurprirnidol, and unriconazole are anti-gibberellic in nature; they allow cell division and growth to occur but suppress cell wall and intemodal elongation;'The advantages and disadvantages and method of applicaboni and use 6f the various TGRs wiere considered&TGRs',like'other vegetation' management tools, do not meet all of the vegetation management needs, but can beintegrated into a comprehensive vegetation management program.

Reference:

ACRT, Inc. 1990.'Tree growth retardants: Literature search synopsis. Empire State Electric Energy*

'-Research Corporation, Schenectady, NY. Research report EP 88-29.'

Page 16 of41 Study Name: ROW herbicide buffer zone efficacy.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO)

Project NamelStudy EP 89-44 Number:

Pi's/Contractors:' KT. McLoughlin, New York Power PooIESEERCO; L.A. Norris, Environmental Consultants Inc., Fort Washington, Pennsylvania.

Period: 1989-1990 Cost:

Purpose and description:

The objective of this project was to test buffer zone effectiveness in protecting stream water quality and evaluate herbicide toxicity to provide a technical basis for establishing water quality protection goals or standards. There were three studies. First was a determination of buffer zone widths needed to achieve water protection goals by comparing herbicide deposition at distances from 0-100 ft from the downwind edge of areas treated by either stem-foliar or basal methods. The second study, a field, test, tested buffer zone effectiveness in protecting water quality using high-volume stem-foliar and low-volume basal applications of picloram, triclopyr, 2,4-D, or imazapyr. Water samples were collected and chemical analysis made. The third study evaluated published literature and other information on the toxicity of herbicides used in the study.

Results:

No buffer or 10 ft buffers were sufficient in protecting water quality where medium to low density vegetation was treated with herbicide. Larger buffer zones were needed where high density vegetation was treated; buffers of 25 ft or more achieve stream water quality criteria. Positive water samples contained concentrations of herbicide of 0.001 to 0.002 mg/l with the highest at .006 mg/A, levels not harmful to humans or aquatic life.

References:

Environmental Consultants, Inc. 1991. Determination of the effectiveness of herbicide buffer zones in protecting water quality on New York State powerline rights-of-way. Empire State Electric Energy Research Corporation, Schenectady, New York. Report EP 89-44.

Norris, L.A., and P.M. Charlton. 1995. Determination of the effectiveness of herbicide buffer zones in protecting water quality. p. 147-152 In G.J. Doucet, C. SUguin, and M. Giguere (eds.) Proceedings of the 5 " Intemational Symposium on Environmental Concems in Rights-of-Way Management, September 19-22, 1993, Montreal, Quebec, Canada, Hydro-Qudbec, Quebec, Canada.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

Page 17 of 41 Study Name: ROW natural growth Inhibitors.

Study Sponsor: Empire State Electric Energy Research Corporation (ESEERCO) and Stud Sposor: Consolidated Edison Co.- of NY, Inc Project NamelStudy EP 90-14 Number:

PI'slContractors: Brooklyn Botanical Garden Research Center, Brooklyn, New York.

Period: 1990 Cost: $40,000 Purpose and description:

The objective was to identify natural compounds and vegetation that inhibit the growth of trees commonly found on New York State transmission line ROWs. The'study included a review of literature pertinent to natural growth inhibitors, emphasizing those natural compounds that affect tree growth,:

including a broad overview of the subject of allelopathy, microorganisms, and tree pathogens.;

Results:

The annotated bibliography highlighted literature pertinent to natural growth inhibitors, including a broad overview of the subject of allelopathy, microorganisms, and tree pathogens. The literature reported approximately 200 phytotoxins from over.100 microbial species, most being produced by fungi. A few of the phytotoxins described in the literature have already been developed as commercial herbicides (e.g., bialaphos and phosphinothricin-the synthetic version is the herbicide Glufosinate).

The development of herbicides from microbially produced phytotoxins is a highly promising area for :

future discovery, which has not been adequately explored. Literature regarding phytotoxins isolated from pathogens of trees is very limited, and those that have been reported were toxic only to the host plant and show little promise as a herbicidelgrowth regulator for a broad range of trees. Articles pertaining to allelopathic effects of one plant on another were also reviewed. Very few investigations of allelopathy found in the scientific literature stood up to the scrutiny of proof required to 'prove" allelopathic effects of one plant on another.

Reference:

Brooklyn Botanical Garden. 1991. Natural growth inhibitors-literature review. Empire State Electric Energy Research Corporation, Schenectady, NY, and Consolidated Edison Company of New York, Inc. Research report EP 90-14.

Page 18 of41 Study Name: Volney-Marcy Rubus study.

Study Sponsor: Niagara Mohawk Power Corporation Project Name/Study Volney-Marcy research project Number Pi'slContractors: C.A. Nowak. SUNY-ESF Period: 1982-1991 Cost: NA Purpose and description:

The objective of this study was to examine the presence of one desirable genus-Rubus-4in response to first and second maintenance cycle herbicide treatments, 1 and 4 years after initial clearing on one recently cleared right-of-way (ROW) in Upstate New York Rubus density and cover were compared among plots treated with herbicides using selective and nonselective basal (triclopyr) and stem-foliar (2, 4-D, picloram and triclopyr) treatment schemes.

Results:

Rubus allegheniensis Porter (common blackberry) was the dominant Rubus species on a recently cleared ROW in Upstate New York. The presence of Rubus was not affected by first maintenance cycle treatments. In response to second maintenance cycle treatments, basal schemes generally had more Rubus than stem-foliar-treatments. In terms of broad plant community stability on ROWs, the role of Rubus is unclear, as are the implications of any differences in Rubus cover among treatments with regard to multiple uses of ROWs;

Reference:

Nowak, C.A. 1991. Volney-Marcy Rubus study. Niagara Mohawk Power Corporation, Syracuse, NY.

NMPC final report.

Page 19 of 41 Name: andlPrinciples practices of vegetation management on electric power Proec - transmission line rights-o-ay.

Study Sponsor: Niagara Mohawk Power Corporation .

Project NamelStudy Volney-Marcy research project.

Number Pl's/Contractors: Abrahamson, L.P. and C.A. Nowak. SUNY-ESF Period: 1989-1992 Cost: $126,649 Purpose and description:

The purpose of this series of studies was to evaluate which application mode and method was most cost-effective in accomplishing vegetation management objectives during early ROW management phases. Treatment plots along ROWs were treated with selective and nonselective basal or cut stump.'

applications of picloram, 2,4-D, and triclopyr and no herbicide treatments in the initial clearing phase, and selective and nonselective basal or stem-foliar applications for the first and second conversion -

cycles. Effects of treatments on desirable woody stem density, undesirable woody stem density, herbaceous cover, undesirable sprouting,' and herbaceous density were evaluated at the end of each conversion cycle. . -. - - -

Results:

During Initial ROW clearing the number of desirable plants was reduced with herbicide treatment, undesirable plants were generally the same between herbicide-treated and no herbicide treatment plots, and costs were higher for herbicide treatments as compared with no herbicide treatment. The most cost-effective method for initial clearing was clear or selective cutting with no herbicide

treatment, During the first conversion cycle there was equal reduction of undesirable vegetation and maintenance of desirable vegetation. Therefore, cost-effectiveness was based on treatment costs alone. Basal treatment costs were nearly double that of stem-foliar with the nonselective mode being less costly than selective; therefore, the nonselective stem-foliar treatment was the most cost-effective scheme. For the second conversion cycle there were more desirable'plants with the selective mode,'

there was a greater reduction in undesirable plants with stem-foliar schemes, and basal treatment costs were nearly double that of stem-foliar. Therefore, selective stem-foliar was the' most cost-w effective herbicide scheme. - - ' - - - -

References:

Abrahamson, L. P., C. A. Nowak, E. F. Neuhauser, C. G. Foreback, H. D. Freed, S. B. Shaheen, and C. H. Stevens. 1991a. Cost-effectiveness of utility rights-of-way vegetation management treatments: I. Initial clearing.AJoumal of Arboriculture 17(12): 325-327.'

Abrahamson, L. P., C. A. Nowak, E. F. Neuhauser, C. G. Foreback, H.-D. Freed, S. B. Shaheen, and C. H. Stevens. 1991b. Cost-effectiveness of utility rights-of-way vegetation'management treatments: II. First maintenance cycle. Journal of Arboriculture 17(12): 328-330.

Nowak, C. A., L. P. Abrahamson, E. F. Neuhauser, C. G. Foreback, H. D. Freed, S. B. Shaheen, and C. H. Stevens. 1992. Cost-effective vegetation management on a recently cleared electric transmission line right-of-way. Weed Technology 6: 828-837.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

a-Page 20 of 41 Study Name of plant dynamics on electric power rights-of-A way in Newappraisal 15-year York State.'

Study Sponsor. Empire State Electric Energy Research Corporation NuPrber u EP 91-16: Rights-of-way stability.

Pi's/Contractors: Abrahamson, L.P., C.A Nowak, and D.J. Raynal. SUNY-ESF Period: 1991-1993 Cost: $147,690 Purpose and description:

The purpose of this 15-year appraisal was to describe long-term changes in tree populations on powerline ROWs across New York with operational vegetation management during the period of 1975-1991.

Results:

Results from the 15-year appraisal indicated that on corridors where trees were periodically, selectively removed using herbicides, tree populations were observed at constant low density. There was a spatial redistribution of trees in 1991 compared to 1975, with fewer trees in the corridor centerline and more in the border areas along corridor edges in 1991. An increase in tree density was observed on corridors that did not receive herbicide treatments to control trees, but had only aboveground portions of trees selectively removed using periodic hand cutting. Species composition generally did not change over the study period. Acer, Betula, Fraxinus, Populus, Prunus, and Quercus species were commonly present on all sites during 1975 and 1991. Red maple (Acer rubrum L.) and white ash (Fraxinusamedcana L.) were ubiquitous. Operational, selective removal of trees on powerline corridors with herbicides, whereby both the above- and below ground portions of the plants are periodically killed and site disturbance minimized, can lead to the creation of relatively stable, compositionally constant, low density tree populations.

References:

Nowak, C. A., L. P. Abrahamson, D.J. Raynal, and D. J. Leopold. 1995. Selective vegetation management on powerline corridors in New York State: Tree density and species composition changes from 1975 to 1991. p. 153-158 In G.J. Doucet, C. Sdguin, and M. Giguere (eds.)

Proceedings of the 5 mIntemational Symposium on Environmental Concerns in Rights-of-Way Management, September 19-22, 1993, Montreal, Quebec, Canada.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

Page 21 of 41 Cost effectiveness of herbicide and non-herbicide alternatives for.

Study Name: vegetation management on powerline corridors in the northeastern United States: A review.

Study Sponsor: Environmental Consultants, Inc.

Project Name/Study NMPC project JC28477AGP.

Number PI'slContractors L.P. Abrahamson and C.A. Nowak. SUNY-ESF P.M. Chariton and P.G. Snyder, ECI Period: 1992 Cost: $34,891 Purpose and description:

The purpose of this series of studies was to assess available information on both herbicide and non-herbicide vegetation management methods for electric utility rights-of-way in the northeastern United States. An extensive search of the literature was conducted, along with mail and phone surveys of utility vegetation managers throughout North America, and on-site visits with several regional utilities.

The study had several general goals, including: (1) review'existing literature, (2) examine experience of utilities that offer special maintenance agreements to landowners who prefer that non-herbicide' methods be employed, and (3) evaluate information from utilities that have experience with long-term no-herbicide-use policies.

Results:

The maintenance of vegetation on electric utility rights-of-way is a dynamic process affected by site conditions, public interest, 'environmental concems, arid costs. Existing information is insufficient to identify one method or group of methods as optimal in all circumstances. Long-term, cost-effective management of ROW vegetation is dependent upon both herbicide and non-herbicide methods; A' prescription-based approach, where'different methods are selected for diff ern't circurnstanices, is the most rational strategy. To effectively manage'this type of program, it is'essential that utilities have well-trained professionals and data to make operational prescriptions in the field.

References:

Abrahamson, L. P., C. A. Nowak, P. M. Chariton, and P. G. Snyder. 1995. Cost effectiveness of -

herbicide and non-herbicide vegetation management methods for electric utility rights-of-way in the Northeast state-of-the art review. p. 27-43 In G.J. Doucet, C. Seguin, and M. Gigubre (eds.)

Proceedings of the 5.' Intemational Symposium on Environmental Concerns in Rights-of-Way Management, September 19-22,1993,-Montreal, Quebec, Canada.

Environmental Consultants, Inc. 1992. Cost effectiveness of herbicide-and non-herbicide-vegetation management methods for electric utility rights-of-way in the Northeast state-of-the art review and annotated bibliography. Abrahamson, L. P., C. A. Nowak, P. M. Chariton, and P. G. Snyder (comps.). Niagara Mohawk Power Corporation, Syracuse, NY. NMPC final project report JC28477AGP.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

Page 22 of 41 S yName:

Study Nm:habitat Utility right-of-way areas. vegetation management in Karner blue butterfly Study Sponsor: Niagara Mohawk Power Corporation Project NamelStudy Number Pi'slContractors: D.J. Leopold, P. Smallidge and L.P. Abrahamson. SULNY-ESF Period: 1994-2002 Cost: $425,000 Purpose and description:

The study was designed to determine the relationship between short and long-term vegetation management on the abundance of blue lupine (Lupinus perennis L.), an herbaceous perennial critical as a food source for the Kamer blue butterfly (Lycaeides melissa samuelis Nabokov)-a U. S. Fish and Wildlife Service listed endangered species-in its larval stages.

Results:

Increased relative light level was the primary variable associated with increased blue lupine abundance. Percent cover of blue lupine was correlated positively with both the recent and longer-term use of herbicides. Blue lupine clump density was most dependent on relative light intensity, and was negatively associated with the number of years since the last management activity and the recent use of herbicides.

References:

Smallidge, P. J., D. J. Leopold, and C. M. Allen. 1995. Management concerns for the response of blue lupine communities on rights-of-way in east-central New York, USA to environmental factors and vegetation management p. 330-335 hr7G.J. Doucet, C. Seguin, and M. Gigu&e (eds.),

Proceedings of the 5 mIntemational Symposium on Environmental Concerns in Rights-of-Way Management, September 19-22, 1993, Montreal, Quebec, Canada.

Smallidge, P.J., D.J. Leopold, and C.M. Allen. 1996. Community characteristics and vegetation management of Kamer blue butterfly (Lycaides Melissa samuelis) habitats on rights-of-way in each-central New York, USA. Journal of Applied Ecology 33: 1405-1419.

Summary compiled from:

Environmental Consultants, Inc. 2001. Integrated Vegetation Management on gas line rights-of-way:

Review of the literature. C.A. Nowak and B.D. Ballard (comps.), Gas Technical Institute, Chicago, Illinois, GRI Report No. GRI-01/0096.

Page 23 of 41 Volney-Marcy electric transmission line vegetation management Project

Title:

project: Third cycle treatments Niagara Mohawk Power Corporation (see individual study descriptions Study Sponsor: for other partners) e -

Project NamelStuc Study No.s 1-11, 15 Number Pi'slContractors: C.A. Nowak, L.P. Abrahamson, and L.W. VanDruff. SUNY-ESF.

Period: 1999-2002

$486,000 (NMPC)

$150,000 (see NYSEG partnership)

Cost: $10,000 (DowAgroSciences)

$4,500 (DuPont)

$25,000 (BASF) ($5,000/year for up to 5 years)

Total:

$675,500 Purpose and description:

This series of studies was designed to evaluate a range of management considerations including:

Long-term effects of non-herbicide treatments and selective and non-selective herbicide treatments on desirable and undesirable woody species dynamics during the second conversion cycle; Methods of reclaiming a ROW (mowing, low volume hydraulic stem-foliar, and cut stump treatment methods); - .

Efficacy and effectiveness of contemporary herbicide treatment methods and mixtures (low volume backpack, low volume hydraulic, basal, and cut stump treatments), and quantification of herbicide use and deposition off-target: disturbance from treatments, duration of impact, opportunity for tree seedling establishment; Ecological considerations: songbird habitat, vascular plant species diversity, competitive ability of low-growing communities: effects on tree growth and development, and a study of gray birch dynamics/ecology.

Results:

See individual study descriptions.

References:

See individual study descriptions.

Page 24 of 41 Study Name: Long-term effectiveness of various herbicide and non-herbicide treatment schehies during the second conversion cycle.

Study Sponsor: Niagara Mohawk Power Corporation Project Name/Study Volney-Marcy electric transmission line vegetation management project Number

Study No. I Pi'slContractors: C.A. Nowak and L.P. Abrahamson. SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management project Cost: Third cycle treatments.

Purpose and description:

The objective of this study was to determine the long-term effectiveness of select treatments applied

'during the second conversion cycle on the Volney-Marcy powerline. Remeasurement of past treatment areas that included selective and non-selective stem-foliar and basal herbicide treatments, brush hog (hydro-axelmowing), and grub and seed treatments was completed in 1999/2000, 11-12 years post-treatment. Desirable and undesirable stem densities by height/diameter class and percent cover for all species were measured using a series of milacre plots and strip transects.

Results:

Over an 11-year period, stem densities were maintained at low levels using selective chemical treatments in an IVM program on the Volney-Marcy powerline' ROW in Upstate New York. Larger.-

trees on the ROW were dominated by gray birch, whereas red maple was the dominant species for smaller seedlings, suggesting that a species shift in undesirable species may be occurring on the Volney-Marcy ROW. Mechanical treatments resulted in higher undesirable densities than chemical treatments. Desirable stem densities have increased or remained constant over time with an IVM approach.

Reference:

Ballard, B.D., C.A Nowak, L.P. Abrahamson, E.F. Neuhauser, and K.E. Finch. Inpress. Integrated vegetation management on electrical transmission rights-of-way using herbicides: Treatment effects over time. In: Proceedings of the 7th International Symposium on Environmental Concems in Rights-of-Way Management. September 9-13, 2001, Calgary, Alberta, Canada.

Page 25 of 41 Effectiveness of various selective herbicide treatment schemes to Study Name: reclaim a ROW.

Study Sponsor: Niagara Mohawk Power Corporation Project NamelStud y Volney-Marcy electric transmission line vegetation rnanagement project Number Study No. 2 Pi'slContractors: C.A. Nowak and L.P. Abrahamson. SUNY-ESF.-

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management project:

Cost: Third cycle treatments.

Purpose and description:

The purpose of this study was to evaluate the effectiveness of selective stem-foliar and cut stump treatments applied to a ROW with tall, low-density undesirable trees.-A'subset of three stem-foliar and three basal treatment areas from Study No. 1 was selected for retreatment 11 years post-treatment.

Stem-foliar treatments were applied coriesponding with historic stem-foliar treatment plots. Cut stump treatment methods were applied to historic basal treatment plots.

Results:

Pending.

Reference:

Pending.

I ML-Page 26 of 41 Vascular plant species diversity before and after first maintenance Study Name: cycle vegetation management Study Sponsor: Niagara Mohawk Power Corporation Project NamelStudy Volney-Marcy electric transmission line vegetation management project:

Number Study No. 3 Pl's/Contractors: C.A Nowak and L.P. Abrahamson. SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management project Cost: Third cycle treatments.

Purpose and description:

Vegetation management on ROWs is conducted to produce values chiefly associated with the safe and reliable transmission of electricity. Secondary values are produced as well. Communities of rare, early successional plant communities can often be found on ROWs. The objective of this study was to determine the effects of selective and non-selective stem-foliar and basal herbicide treatments on plant species diversity during the second conversion cycle.

Results:

Pending.

Reference:

Pending.

Page 27 of 41 Study Name: Competitive hierarchies of desirable plant communities.

Niagara Mohawk Power Corporation Study Sponsor: New York State Electrc and Gas Corporation -

Project NamelStudy Volney-Marcy electric transmission line vegetation management project Number Study No.4 (NYSEG Study No. 4)

Pi'slContractors: C.A. Nowak and L.P. Abrahamrson.'SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission lrin vegetation management project Cost: Third cycle treatments'.

Purpose and descril Wtion:

Vegetative commuiities found on powerline ROWs vary in'their ability to inhibit undesirable tree seedling establishment,: survival, and growth. The purpose of this study was toevaluateeach of these suppression factors for important vegetative communities found on the Volney-Marcy-ROW. To better understand the stability of these community types, two approaches were employed in this study: 1).:

stem analysis and 2) seedling demography of trees growing in each community type. -

Results:

Pending.

Reference:

Pending.

I- -- a-Page 28 of 41 Study Name: Herbicide deposition patterns for commonly used treatment schemes.

Niagara Mohawk Power Corporation, New York State Electric and Gas Study Sponsor: Corporation, Dow AgroSciences, DuPont, BASF.

Project Name/Study Volney-Marcy electric transmission line vegetation management project Number Study No. 5 (NYSEG Study No. 6)

PI'slContractors: C.A. Nowak and LP. Abrahamson. SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management project Cost: Third cycle treatments.

Purpose and description:

Work on this study corresponds with low volume backpack foliar treatment applications in Study No. 8 and cut stump treatments in Study No. 10. One concern with herbicide is that there are detrimental effects on non-target vegetation (communities) due to overspray. This objective of this study was to quantify the amount of herbicide used to treat varying densities and sizes of trees and to quantify the amount of overspray that results for conventional herbicide methodslapplication techniques.

Results:

Pending.

Reference:

Pending.

Page 29 of 41 Site-specific and landscape-level effects of ROW vegetation t Study Name: - management onsongbird communities.*

Study Sponsor: Niagara Mohawk Power Corporation Project NamelStudy Volney-Marcy electric tranismission line vegetation management project Number Study No. 6 PlI'sContractors: L.W. VanDruff. SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management project:

Cos:*Third cycle treatments.

Purpose and description:

Powerlini ROWs may serve as suitable habitat for a number of shrub bird species currently in decline because of the loss of agriculture and reversion of old fields back to forest in the northeiastem'United '

States. The potential quality of that habitat will largely reflect the vegetation management strategy' employed in any given ROW. The objective of the study was to'determine what the site-'spe'cific effects of vegetation mnanagement were on sohgbird communities. Two of the primiary vegetation management strategies-are mechanical treatments and selective herbicide treatments.'The bird' '

community of a ROW in which both treatments were used on one or the other of two side-by-side powerlines was studied usinga combination of spot-mapping, nest searching, and vegetation '-

measurements. '-

Results: '

There was a difference in shrub density on the two powerlines; the older Fitzpatrick-Edic line, with a history of mechanical treatments, had a higher shrub density than the youngerVolney-Marcy' powerline. There were two times more bird territories and nests in high shrub density areas.

Songbirds respond directly to shrub habitat on ROWs; as shrub density'increases, shrub iestinrg birds increase. Once'established, the permanence of the plant community produced withselective' -

herbicides may be better for short-lived bird species than the regular destruction of the plafit-'

community required in mechanical treatments.

Reference:

Marshall, J.S., L.W. VanDruff,'and S.D. Shupe. Inpress. Effects of Power Line Right-of-Way Vegetation Management on Avian Communities. In: Proceedings of the 7th Intematibonal Symposium on Environmental Concerns in Rights-of-Way Management. September 9-13, 2001, '

Calgary, Alberta, Canada.

t Page 30 of 41 A study of the invasion and growth patterns of Betula populifolia Study Name. Marsh. (gray birch) on a powerilne ROW in New York State.

Study Sponsor: Niagara Mohawk Power Corporation Project NamelStudy Volney-Marcy electric transmission line vegetation management project Number . Study No. 7 Pi'slContractors: C.A. Nowak and L.P. Abrahamson. SUNY-ESF.

Period: 1999-2002 Cost: See project Third cycle electric Volney-Marcy transmission line vegetation management treatments.

Purpose and description:

Gray birch (Betula populifolia Marsh.) is an important tree species on powerline ROWs in the north temperate zone of North America. It is a pioneer species that can proliferate in the early plant succession environment of powerline ROWs. While a short tree at maturity (10- to 15-meters), it is commonly a danger for the transmission of electricity..This study was initiated to determine why gray birch was so prevalent on the Volney-Marcy ROW, 17 years after initial clearing. Stem densities of the gray birch population (trees greater than,1 cm diameter at breast height and approximately 3 m height) averaged 350 ha". 11 years post-treatment (second treatment cycle). Treatments were basal and stem-foliar herbicides applied using non-selective or selective modes as part of a long-term study.

Fifty-four gray birch trees from across a 25 km section of ROW were examined for height-age development pattems. Population density and age structure were measured on 11 treatment plots.

Results:

Gray birch tree heights ranged to over 11 m and tree ages from 4 to 1,3 years. Most of the trees were established within 3 years after treatment. Young powerline corridors that have mesic to hydric moisture regimes are well-suited to birch invasion, particularly with management-related disturbance.

Minimizing'site disturbance and promoting the development of a tall shrub community should reduce birch presence on older powerlines.

Reference:

Nowak, C.A, B.D. Ballard, and E. O'Neill. In press. Gray Birch Ecology on an Electric Powerline Right-of-way in Upstate New York. In: Proceedings of the 7th Intemational Symposium on Environmental Concems in Rights-of-Way Management, September 9-13, 2001, Calgary, Alberta, Canada.

Page 31 of 41 Effectiveness of various herbicide treatment schemes on ROWs that Study Name: were operationally treated during the last treatment cycle.

Niagara Mohawk Power Corporation, New York State Electric and Gas Corporation, Dow AgroSciences, DuPont, and BASF. - - L Project NamelStudy. Volney-Marcy electric transmission line vegetation management project Number Study No. 8 (also NYSEG Study No. 5)

PI'slContractors: CA. Nowak and L.P. Abrahamson. SUNY-ESF.'

Period: . 1999-2002 ,

See Volney-Marcy electric transmission line vegetation management project Cost: Third cycle treatments.

Purpose and description:-

The objective of this study was to compare the effectiveness of low volurme backpack foliar, low, volume hydraulic stem-foliar, and basal treatments under conditions that are routinely encountered on managed powerline ROWs. Three herbicide mixtures were used for the backpack foliar treatment Accord/Arsenal, Tordon/Garlon, and Krenite/ArsenaUlEscort. Two herbicide mixtures were used for .

hydraulic foliar. Tordon/Garlon and Accord/Arsenal. A single herbicide mixture was used for basal treatments: Garlon/Arsenal. Sites were selected from operationally treated areas with an area of approximately I acre for each of the six treatments and stem densities of 50-200 undesirable stemsiacre over 6 feet in height. In addition to quantifying treatment effectiveness, treatment methods in this study will be evaluated for herbicide deposition patterns and the impact on non-target vegetation (Studies 5 and 9).

Results:

Pending

Reference:

Pending

Page 32 of 41 Herbicide deposition patterns for commonly used treatment schemes:

Study Name: Impacts on community structure and composition in the near- and long-term.

Niagara Mohawk Power Corporation, New York State Electric and Gas Study Sponsor Corporation, Dow AgroSciences, DuPont, and BASF.

Project NamelStudy Volney-Marcy electric transmission line vegetation management project Number Study No. 9 (NYSEG Study No. 6)

Pi'slContractors: C.A Nowak and L.P. Abrahamson. SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management project Cost: Third cycle treatments.

Purpose and descripition:

Work on this study corresponds with the treatment applications in Studies No; 2 and 8. The purpose of this study was to quantify the area affected by the 'overspray shadow", and to assess the impacts that the overspray has on the vegetative community soon after treatment and over time. The areas impacted from "overspray" were quantified by delineating and mapping these areas for a total of 30 trees for each treatment method studied.

Results:

Pending

Reference:

Pending

Page 33 of 41 Study Name: Expanding the treatment window for cut stump herbicide treatments.

Study Sponsor: Niagara Mohawk Power Corporation ;

Project NamelStudi' Volney-Marcy electric transmission line vegetation management project:

Number Study No. 10 Pi's/Contractors:' CA Nowak and LP. Abrahamson. SUNY-ESF.

Period: 1999-2002 Cost: See Volney-Marcy electric transmission line vegetation management project Third cycle treatments.

Purpose and description:

The purpose of this study was to evaluate the efficacy and effectiveness of three cut stump herbicide mixtures, Accord/Arsenal, Garlon 4lStalker, and Pathway, applied at three different times during the year early spring (April), mid-summer (June),-and late fall (November).

Results:

Pending

Reference:

Pending

Page 34 of 41 Study Name: Effectiveness of mowing to reclaim a previously mowed ROW.

Study Sponsor: Niagara Mohawk Power Corporation Project NamelStudy Volney-Marcy electric transmission line vegetation management project Number Study No. 11 Pi'slContractors: C.A. Nowak and LP. Abrahamson. SUNY-ESF.

Period: 1999-2002 See Volney-Marcy electric transmission line vegetation management Cost: project Third cycle treatments.

Purpose and description:

Mowing has often been used on ROWs in New York State. This study evaluated the effectiveness of mowing and mowing with follow-up stem-foliar herbicide treatment(s) to reclaim a ROW that has gone untreated for 11 growing seasons. Ten mowing (hydro-ax) treatment areas were retreated in late June 2000 using a Hydro-Ax 621 E skidderwith a Rotary Ax mower deck. As of August. 2001, follow-up herbicide treatments have not yet been prescribed Results:

Pending

Reference:

Pending

Page 35 of 41 Demonstration of ROW Vegetation Management Tools on a ROW near Study Name: Albany, New York.

Study Sponsor: Niagara Mohawk Power Corporation Project Name/Study Volney-Marcy electric transmission line vegetation management project Number . Study No. 15 PI'slContractors: C.A. Nowak and L.P. Abrahamson. SUNY-ESF.

Period: 2000-2002 -

See Volney-Marcy electric transmission line vegetation management project:

Cost: Third cycle treatments.

2001 Environmental stewardship of utility rights-of-way conference cost: $?

Purpose and description:

The purpose of this study area was to provide a showcase of vegetation management tools and strategies that would be readily accessible in the Albany area. The demonstrationlresearch area was established June'2000. Twelve 1-acre areas were delineated on a hillside west of the New Scotland substation off Route 308, approximately 5 miles southwest of Albany. Pre-treatment measurements were completed in each 1-acre area, which included establishing nine milacre plots and six strip transects (six-feet wide x 66-feet long). The area had high shrub presence, including gray dogwood, honeysuckle, and multiflora rose, and had a suitable number of medium to large undesirables ready for treatment. Treatments were applied in mid-June, 2001 Results:

Vegetation management treatments were demonstrated at the site for the Environmental stewardship '

of utility rights-of-way conference held in Albany, NY in June 12-13, 2001. The event was hosted by Niagara Mohawk Power Corporation, Energy Alliance-of New York, and the State University of New York College of Environmental Science and Forestry (SUNY-ESF). The workshop participants included professionals from the utility industry, regulatory agencies, environmental analysts, and universities. Presentations were made by the utilities: NMPC, New York Power Authority, and New York State Electric and Gas. The agency perspective was presented by the New York State Department of Environmental Conservation and the Public Service Commission. SUNY-ESF presented a review of current research and a new framework in which to think about Integrated Vegetation Management.

Reference:

NA

U Page 36 of 41 Shrub community dynamics on a powerline corridor in upstate New Project

Title:

York.

Niagara Mohawk Power Corporation, Electric Power Research Institute, and Study Sponsor: New York State Electric and Gas Corporation.

Shrub community dynamics on a powerline corridor in upstate New Project Name/Study York/Volney-Marcy electric transmission line vegetation management project:

Number Study No.s 12-14 Pi's/Contractors: C.A. Nowak, L.P. Abrahamson, and B.D. Ballard. SUNY-ESF.

Period: 2000-2002 Cost:. $135,095 (also see NYSEG partnership)

Purpose and description:

The purpose of the three studies in this project was to answer three main questions about shrub ecology: 1) What is known about the life histories (reproduction, growth, and longevity) of common ROW shrubs (Comus, Rubus and Viburnum)? 2) What factors have influenced the distribution and abundance of shrubs on powerline ROWs? and 3)What cultural treatments can increase and maintain the presence of desirable shrub communities (Specifically, mowing or coppicing of arrowwood, Vibumum dentatum, and gray dogwood, Comus racemosa)?

Results:

See individual study descriptions.

Reference:

See individual study descriptions.

Page 37 of 41 Study Name: Select shrublife histories- An annotated bibliography.

Study Sponsor: Niagara Mohawk Power Corporation and Electric Power Research Institute.

Project NamelSt Shrub community dynamics on a 0oweriine 'corridor in upstate New Pjet Na udy York/Volney-Marcy electric transmission line vegetation management project: -

Number: - Study No. 12 Pl's/Contractors: CA Nowak, LP. Abrahamson, and B.D. Ballard. SUNY-ESF.

Period: 2000-2002 Cost: See Shrub community dynamics on a powerline'corridor in upstate New Purpose and description:

The objective of this study was to develop an annotated bibliography that contains' references important to the ROWvegetation manager in understanding the life histories (reproduction, growth; and longevity) of common'shrubs (Comus sop., Rubus spp., and Vibumumn spp.) in the northeastern United'States. A review of the literature was conducted to assess the state-of-knowledge about shrub life histories of common shrub species, f6cusing on Comus racemosa Lam'., Viburnum dentaturn spp.

L, V. lentago L., RubLs idaeus spp. L.,.anid R. allegheniensis T.C. Porter, based on'prominence in the' region and vegetation management literature. The annotated bibliography includes summaries of 77 articles. . :

Results:

Synopsis pending.

Reference:

Ballard, B.D., C.A. Nowak, H.L. Whittier, P.J. Donoso, J.C. Deegan, and J.W. Goodrich-Mahoney. Life Histories of Common Shrubs on Utility Rights-of-Way in the Northeastem United States: An Annotated Bibliography. In press (2001). Electric Power Research Institute, Palo Alto, CA-and Niagara Mohawk Power Corporation, Syracuse, NY.

Page 38 of 41 Factors Influencing the distribution and abundance of shrubs on ROWs Study Name: in New York State: An observational study.

Niagara Mohawk Power Corporation, Electric Power Research Institute, and Study Sponsor: New York State Electric and Gas Corporation.

Shrub community dynamics on a powerline corridor in upstate New Project Name/Study YorkNolney-Marcy electric transmission line vegetation management project Number: Study No. 13 (NYSEG Study No. 2)

Pi'slContractors: C.A. Nowak, LP. Abrahamson, and B.D. Ballard. SUNY-ESF.

Period: 2000-2002 Cost: See Shrub community dynamics on a powerline corridor in upstate New York.

Purpose and description:

Species composition and abundance of shrub communities on various ROWs appear to vary as a function of site quality and land use history. The distribution, composition, and abundance of shrub/herb communities found on ROWs are a function 6f physiographic (site) conditions, past land use and treatment history, adjacent land use, and age of the .ROW. The objective of this study is to explore and determine what factors have the greatest influence on the distribution and abundance of shrubs on powerline ROWs across New York. Management of shrub communities can be adjusted to meet management objectives based on an understanding of the factors that influence shrub dynamics.

Results:

Pending.

Reference:

Pending.

Page 39 of 41

-Assessment of cultural treatments to Increase and maintain the Study Name: presence of desirable shrub communities: A manipulative field experiment.

Niagara Mohawk Power Corporation, Electric Power Research Institute, and Study Sponsor: New York State Electric and Gas Corporation.

Shrub community dynamics on a powerline corridor in upstate New Project NamelStud Iy YorkNolney-Marcy electric transmission line vegetation management project:

Number: Study No. 14 (NYSEG Study No. 3)

Pi'slContractors: C.A. Nowak, L.P. Abrahamson, and B.D. Ballard. SUNY-ESF.

Period: 2000-2002 Cost: See Shrub community dynamics on a powerline corridor in upstate New -

Cost:York.

Purpose and description:

While shrub communities are generally viewed as the most effective desirable plant community at minimizing colonization by undesirable, tall-growing trees, there is much to learn about shrub community dynamics. The objective of this study was to determine what cultural treatments and by what mechanisms can the presence of desirable shrub communities be increased and maintained on ROWs. Both vegetative and sexual reproduction strategies may be necessary for many shrub species to effectively colonize a site. However, there are cultural practices that may promote vegetative reproduction or spread (e.g., via basal sprouting, root suckering, etc.). Higher shrub density and cover have been observed on ROWs that have a history of mowing or handcutting (alone or in combination with cycles of chemical control) than on ROWs that were managed using only selective chemical treatments (herbicides). This study evaluates the impact of mechanical treatments (mowinglhandcutting) on shrub dynamics of arrowwood, Viburnum dentatum, and gray dogwood, Comus racemosa.

Results:

Pending.

Reference:

Pending.

U-_

Page 40 of 41 Vegetation dynamics on operationally treated powerline corridors Study Name: across New York state: 25-year re-assessment of Niagara Mohawk lines.

Niagara Mohawk Power Corporation and New York State Electric and Study Sponsor: Gas Corporation.

Nuber:NamelStUdy.

Project NStudy No. 16 (also NYSEG Study No. 1)

Pi'slContractors: C.A. Nowak and B.D. Ballard. SUNY-ESF.

Period: 2002-2004 Cost: $93,857 (also see NYSEG partnership)

Purpose and description:

The purpose of monitoring the long-term effects of operational vegetation management on New York's powerline ROWs is to improve vegetation management and assure stakeholders that treatments are creating desired conditions. New York State utilities have periodically assessed the state-wide condition of ROWs vegetation; in this study a series of permanent vegetation management plots-originally established in 1975 and re-measured in 1991-on ROWs across the state will be re-assessed at the 25-year mark in 2002-2004.

Results:

Pending.

Reference:

Pending.

Page 41 of 41 Project Name: Partnerships for powerline vegetation management in New York.

Study Sponsor: New York State Electric and Gas Corporation Project NamelStudy Study No.s1-6 (also see NMPC's Volney-Marcy electric transmission Number: line vegetation management project)

Pi's/Contractors: C.A Nowak, L.P. Abraharmson, and B.D. Ballard. SUNY-ESF.

Period: 2000-2003 Cost: $150,000 Purpose and description: .I This partnership supplements and extends the life of many of the studies described in NMPC's Volney-Marcy electric transmission line vegetation management project, including:

Vegetation conditions on operationally treated powerdine corridors across New York State: 25-year re-assessment (NMPC Study No. 16/NYSEG Study No. 1) -

Shrub ecology on electric transmission line ROWs in New York State-observational field study (NMPCIEPRI Study No. 13INYSEG Study No. 2)

Shrub ecology on electric transmission line ROWs in New York State-manipulative field experiment'-

(NMPC/EPRI Study No. 14/NYSEG Study No. 3) .

Competitive hierarchies of desirable plant communities (NMPC Study No. 4INYSEG Study Nc. 4)

Effectiveness of contemporary herbicide treatment schemes (NMPC Study No. 8INYSEG Study No.

5)

Herbicide deposition patterns for commonly used treatment schemes. (NMPC Study No.s 5 &

91NYSEG Study No. 6)

Results:

Pending.

Reference:

Pending.

Page 1 of 11 Study Name: Vegetation management on utility rights-of-way.

Results:

The annotated bibliography contained 279 references and serves as one of the first comprehensive state-of-the-art literature reviews for vegetation management on utility ROWs. Approximately half of the references pertain to the use, effects, or safety of herbicides. The remainder of the references dealt with general ROW issues, vegetation management, methods and procedures of vegetation management, and wildlife benefits.

Cody (1975) concluded: Economic and environmentally acceptable maintenance of transmission line rights-of-way is a matter of great concern for power companies. While everyone agrees that some sort of vegetation management is necessary, there is a wide difference of opinion as to the most economic and environmentally acceptable method. After examining the literature, talking with many right-of-way.

managers and examining many rights-of-way, the following conclusions were reached:

1. Right-of-way vegetation management should start with initial clearing. Proper initial clearing can greatly reduce future maintenance costs and provide a more environmentally acceptable right-of-way.

2. While initial clearing is important, the greatest job confronting the right-of-way manager is maintenance of existing rights-of-way.

3. A great variety of conditions exists on rights-of-way requiring a variety of treatments to achieve desired results. The need for maintenance should be determined by line examination, and treatment should be' prescribed according to species and conditions.

4. While mechanical methods of woody plant control are still needed and are being used, by far the most right-of-way treatment is done using chemical methods.

5. There are two general methods of applying chemicals: broadcast spraying and selective spraying.

While more acreage is probably being treated by broadcast methods at present (1975), selective methods are gaining rapidly.

6. Basal spraying is the most selective methods of chemical application, but other methods can also be used selectively; exceptions are helicopters, fixed boom sprayers and mounted mist blowers.

7. Preservation and development of stable low-ground cover is, in the long run, the most economical method of vegetation management. It can be developed and maintained by selective spraying.

8. Where vegetation is dense, initial treatment by broadcast spraying may be the only practical way to reduce density and prepare the way for selective maintenance.

9. In remote areas or extremely rugged terrain, broadcast spraying by helicopter may be the only practical means of vegetation control. It may also be justified in certain other situations such as emergency conditions, shortage of labor, or where all, or nearly all, of the woody vegetation on a section of right-of-way is of an undesirable species.

10. Right-of-way maintenance success is highly dependent upon the preparation of good vegetation management plans, and reliable resources to carry them to completion.

Page 2 ot 11 Environmental and economic aspects of contemporaneous electric transmission line rightof-way management techniques.

Results:

Case histories of 22 rights-of-way managed using commonly accepted methods were&carried out in New York State. Study sites were located in all major forest regions of the state. Vegetation management over the previous decades on these ROWs fostered the development a complex of -

shrub-herb-grass communities. Shrubs found in adjacent forests to the ROW were prominent components of the ROW cover. Tree species continued to invade the ROW even with an established cover of shrubs, herbs, ferns, and grasses. This pressure from invading trees, if left unmanaged, would re-establish forest cover. Characteristic plant communities were developed in relation to habitat and were identified as: blackberry-goldenrod or sumac-goldenrod on mesic habitat areas; blueberry-sweetfem or blueberry-bracken fern on xeric areas; and willow-sensitive femr red-osier dogwood-sensitive fem, or spirea-sensitive fern on hydric areas. ROW management has improved wildlife food -

and cover conditions and plant species diversity. Species diversity was consistently higher on the ROWs than in adjacent forests. Impacts of ROW management on erosion and stream water were negligible; construction disturbances were the exception. Generally, there 1wai little charie in--,

adjacent land use to the ROWs since ROW construction.

Study Name: Cost comparison of right-of-way treatment methods.

Results:

The effect of seven treatment methods-hand cutting, mowing, cut stump, dormant basal, summer basal, selective ground foliar, and aerial-on capable tree densities varied. In the high density class -

all treatments decreased density. Medium density class increases were observed in segments treated with hand cutting, mowing, and cut stump methods. Mechanical treatments produced stem reductions..

of <60% at all densities. Cut stump was most effective at high densities. Dormant basal, summer .

basal, and aerial treatments exceeded 60% stem reduction at medium and high densities but only summer basal was as effective at low density. Selective ground foliar reductions were 71%, 100% and 59% at high, medium, and low densities, respectively. All treatments produced >60% reduction in mean height on both high and low height sites. Based on a single application of treatments, hand cutting, cut stump, and mowing were lessex4nsive than basal spray trIatDents raing fromrS91'

$159, $113-$309, and $162-5193, respectively, depending on stem density. No highly adverse ;

impacts on wildlife habitat were caused by any of the ROW treatments. Cost and effectiveness comparisons of girdling, frilling, basal injection, and stem injection found girdling to be the least desirable method Study Name: The effects of right-of-way vegetation management on wildlife habitat.

The objective of this project was to summarize the knowledge of the effects of standard ROW vegetation management practices on various wildlife 'species and their attendant habitats in New York State. The supporting objectives of this project were to: (1) conduct a review of pertinent literature, (2) identify ongoing related research, (3) identify both positive and negative impacts on wildlife habitats,'

and (4) determine gaps in the knowledge. '

This project examined the'available data6combining it with expert analysis and opinion in order to make predictions about consequences of alternative management actions. This was accomplished by conducting a thorough state-of-the-art literature review including a summary of ongoing research and a survey of unpublished data.

Results:

Initial impacts of ROW vegetation management are usually less favorable to wildlife than the long-term impacts. Treatments performed upon ROWs with high tree densities resulted in an immediate reduction in food and cover available to wildlife, whereas selective treatments on ROWs with a low or medium density of trees resulted in minimum reductions. Successfully managed ROWs that develop

I ~I-Page 3 of 11 relatively stable shrub/herblgrassland plant communities benefit a wide variety of wildlife species.

Vegetations management on ROWs encourages a broad spectrum of wildlife species, though the habitat requirements of all species cannot be met, thereby discouraging some species.

Study Name: ROW multiple uses.

Results: - -

The final report summarized all available literature on ROW multiple uses and included an annotated bibliography; A summary of survey responses was also presented. Analysis of this information provided summaries on such topics as utility multiple use policies, compatibility of uses, management strategies to control incompatible uses, accommodations of complaints, risk assessment, legal implications, management prerogatives to encourage compatible uses, compatibility criteria, and the current management of multiple use by the ESEERCO member systems as well as regulatory perspectives on these issues.

Study Name: Long-term right-of-way effectiveness.

Results:

Based on three density classes, high, medium, and low, a comparison of effectiveness of seven ROW treatments-hand cutting,' mowing, cut stump, dormant basal, summer basal, aerial, and selective ground foliar-on undesirable plants (trees) was' performed. Hand cutting was followed by an increase for all density classes. Mowing was followed by 44, 13, and 29% decreases in the three classes, respectively. Cut stump showed 71, 48, and 8% decreases, dormant basal was followed by 75, 57, and 63% reductions for each class, summer basal had 76, 83, and 57% reductions, selective ground foliar showed 81, 67, and 41% density decreases, and aerial treatment was followed by 81,74, and 68% decreases in stem density for the three classes, respectively; A correlation of treatment effectiveness and initial stem density, the relationship of the height of capable trees to the effectiveness of the treatments, and the effectiveness of treatments on common capable tree species is also discussed.

Study Name: Right-of-way treatment cycles.

Results:

Fifty-four percent of the study sites treated using seven treatment methods-hand cutting, mowing, cut stump, dormant basal, summer basal, selective ground foliar, and aerial-had a 3 yr treatment cycle, 24% had a 4 yr cycle, 18% had a 5 yr cycle, and 4% had a 6 yr cycle. For sites with a 3 yr cycle, hand cutting showed an increase in stem density by 14%. Summer basal showed the greatest density change with a 76% reduction. At the end of the treatment cycles,' ROW sites treated with-summer basal had the greatest reduction in density and the lowest density of all the treatment types.

All other treatments reduced density except hand cutting, which showed 'an increase and had the highest average density of all treatment types. The average' capable height was effectively the same at the time of retreatment regardless of which treatment was used. Cut stump had the greatest reduction in capable species height while selective ground foliar showed the greatest increase in capable species height Total shrub cover increased following all treatments, with selective ground foliar and dormant basal showing the best results. Aerial treated sites showed the greatest increase in herbaceous plant cover, while summer basal showed the least.

Page 4 of 11 Study Name: ROW effects from herbicide residues. -

Results:

The primary parameters which characterize potential herbicide behavior in the terrestrial environment are the soil adsorption coefficient, aqueous solubility, vapor pressure, degradation rate in soil, and dissipation rate from leaf surfaces. The simulations/modeling approaches were'determnined to be suitable for predicting herbicide mobility anid residues consistent with observed field studies reported in the literature; -'

~1 -. ..

Study Name: Herbicide mobility study.

Results:

Overland flow of herbicides in runoff did not occur under normal conditions, but two off ROW soil samples did contain detectable levels of herbicide. In both instances, the herbicide application was -'

immediately followed by rainfall. The linear extent of overland flow was minimal, and when it occurred, the herbicide degraded rapidly. After thelnitial application, there was no indication that overland' migration of herbicide off the site was occurring. 'Rather, the trend was towards degradation of' herbicides to undetectable levels. Entry into streams from overland flow is highly unlikely when appropriate non-treatment buffer zones are'established adjacent to water resources, as is entry into wells or groundwater through leaching. Leaching to a depth of 10-15 inches of herbicides on the sprayed sites was rare, occurring only'at three'locations. The leaching likely occurred under three types of circumstances: (1)rainfall immediately after application,:(2) a large amount of rainfall within a' day after application, and (3)the basal application of a high concentration of herbicides'to asingle

spot on the site. Herbicide concentrations in seepage from the top 6 inches of soil followed similar trends'in mobility and persistence in soil samples. Drift of herbicides off the treated right-of-way did not occur during the study, because non-volatile herbicides were used and were carefully applied using proper techniques.

During the study, the herbicide 2,4-D did not persist past four weeks; Picloram did not persist past ten weeks. Triclopyr applied by the'foliar rmiethod inma water carrier did not persist past ten weeks',-

Triclopyr applied by the basal method in an oil carrier persisted up to 18 weeks. This 'unusual length of' persistence likely resulted from the high initial herbicide concentrations in'localized spots associated with the application method. Because the herbicides biodegrade'rapidly, the possibility of movement.:'

of the material into adjacent water resources isgreatly diminished, especially when proper buffer zones are established.

Study Name: Right-of-way chemical treatments-site preparation.

Results:

Site preparation using handcutting resulted in an average treatment time of about 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per acre for, all 30 units. The averages of manhours based on vegetation density were: 6.2 (high), 3.1 (medium),

1.8 (low) . For vegetation in the high density category, the average handcutting times based upon -

topography were 7.4 (steep),' 6.5 (sloped), 5.8 (level). The average manhours per acre for all hand disposal units was 5.3. Averages of hand disposal manhours based upon vegetation density were 9.8 (high), 3.9 (medium) and 1.2 (low).-The average hand disposal times on high density units based upon topography differences were 13.4 (steep), 9.5 (sloped) and 3.3 (level). The average machine disposal manhours was only 1.8 per acre but significant equipment costs were also incurred for-this technique.-,

U Page 5 of 11 Project Name: ROW vegetation dynamics.

Results:

Summary of fifteen studies compiled from Institute of Ecosystem Studies (1993, p. 341-353):

ROW vegetation is often extremely diverse, and is an important component of overall landscape diversity, particularly in heavily forested landscapes. ROW vegetation is commonly 'patchyl, producing mosaics of small communities that differ in composition, structure and dynamics. On undisturbed ROWs, shrub cover is increasing, particularly for gray dogwood on moist sites. Gray dogwood appears capable of establishing and maintaining long-term dominance of a site if invading trees are systematically and selectively removed.

Tree invasion is directly proportional to the number of seeds dispersed into a site, and resistance by shrubs does not appear to be density dependent, though seed predation may be. Sapling emergence will vary significantly from year to year and site to site due to pulses in seed production; cohorts of seedlings will emerge 10-40 years after such a pulse. Most new tree invasion along ROWs in the Hudson Valley comes from large-seeded, wind-dispersed species (i.e., maples and ashes), and secondarily from large-seeded, animal dispersed species (i.e., oaks). Light-seeded, widely dispersed, apioneer* tree species appear to be effectively inhibited by intact ROW vegetation. Dormant tree seeds buried in the soil are not an important source of seedlings for any of the common trees invading ROWs in the Hudson Valley. The adjacent forest community has a significant effect on the species and the rate of trees invading the ROW. On ROWs wider than 30 meters (100 ft.) that are borddred by.

forests, rates of tree invasion will be highest adjacent to the edges and drop off at distances greater than 15 meters from the forest edge.

Natural mortalityreduces tree density throughout the process of invasion-from the time of arrival of seeds to sapling emergence. Tree invasion is not limited to disturbanceswithin ROW vegetation. Tree seedlings exploit natural variability in resource availability within ROW vegetation. However, the heterogeneity per se does not appear to be an important determinant of overall rates of invasion (i.e.,

successful invasion on favorable microsites is offset by poor survival of tree seedlings in unfavorable microsites). Tree seedling density is not necessarily a good predictor of the number of seedlings that will survive to sapling size because the factors that determine seedling establishment often appear to be inversely related to the factors that determine subsequent survival. Rates of tree invasion are highly sensitive to small changes in growth and mortality of older seedlings (i.e., small differences among communities in annual rates of growth and survival of older seedlings have a significant effect on overall rates of invasion).

The net competitive effects of low-growing communities on tree seedling growth and survival are the result of the combination of (1) the effects of low growing communities on the availability of resources essential for seedling growth; and (2) the responses of tree seedlings to variation in resource availability. There are fundamental differences in the degree to which the specific resources (light, moisture and nutrients) required for tree seedling growth can be depleted by low-growing communities. Low-growing communities differ significantly in the amount of shade they cast. There was little evidence that the communities differ in the degree to which they deplete the availability of water. There is considerable variation among the low-growing communities in the supply of nitrogen (from the decomposition of organic matter in the soil). The effects of ROW vegetationon tree seedling growth and survival can be both positive ('facilitation") and negative(inhibition"); the net effect will depend on the balance over the period from seedling establishment to sapling emergence, but will vary depending on the physiology and ecology of individual tree species (e.g., shade tolerant versus shade intolerant species).

The intensity of competition between ROW vegetation and tree seedlings varies directly with site quality. The net negative effect of ROW vegetation on seedling growth is greatest on productive soils.

On physically stressful sites, seedlings grow slowly even in the absence of intact vegetation. As a result, competition and physical stress tend to balance one another, resulting in relatively low growth

Page 6 of 11 rates for newly established seedlings, regardless of community type or site quality. One implication of this result is that disturbance to the intact vegetation will be particularly detrimental on productive

sites, where seedlings can rapidly exploit any openings. In contrast, poor quality sites may be less sensitive to short-term disturbance because physical stress severely limits early seedling growth and survival of most species even in temporary openings in ROW vegetation. Thus, the'duration of -

competition (i.e.' the number of years it takes for a seedling to overtop the ROW vegetation) is more important to tree invasion thai the intensity in any given year (e.g., shrub cover can depress seedling growth longer than herbaceous communities). ROW vegetation inhibits tree seedling growth through competition both aboveground (for light) and belowground (for water or nutrients).'Most low-growing communities on most sites inhibit tree seedling growth through simultaneous limitation of the availability of both light and soil resources. Aboveground competition will often be the predominant interaction on productive sites, while belowground competition is greatest on mrore stressful sites. This reinforces the conclusion that productive sites will be the most sensitive to disturbance to the canopy of ROW vegetation.

Seed predation, primarily by white-footed mice, is frequently an important source of mortality for seeds that are dispersed into'rights-of-way. Short-term rates of seed predation are higher under shrubs than in' herbaceous dominated communities, presumably reflecting the.

habitat preferences of white-footed mice. Seedling'predation (outright mortality of seedlings due to consumption), primaily by meadow voles, is a potential major source of mortality for tree seedlings.

Rates of seedling predation are greatest when' meadow vole population densities ar'e high; but -

significant'predation occurs even at low vole population densities. Seedling predation by meadow' voles may be restri6ted to herb aceous cmmunities that provide suitable habitat. 'Therefore, the.

relative importance of seed predation versus seedling predation may vary significantly as a function of, the amount of woody cover within a site. Mammalian browsing on tree seedlings, by both white-tailed deer and eastern cottontail rabbits, significantly reduces the rate of tree invasion in most ROW communities. Deer browsing within rights-of-way is highest in heavily forested landscapes. Browsing rates are highest on seedlings that are not overtopped by adjacent shrubs or herbaceous species. -..

The effects of browsing on seedling growth and mortality depend strongly 'on'the timing and intensity -

of browsing, and the levels of other stresses experienced by a seedling. Even heavy winter browsing of unshaded seedlings for 2 successive years has little effect on either growth or survival of tree seedlings. Whereas summer browsing has significant effects on seedling growth and survival.

Overall rates of tree invasion in any given community reflect the net results of a large6number of processes (i.e. seed dispersal, seedling establishment, first-year seedling survival, etc.) Shrub' communities had the highest resistance to tree invasion of the communities examined in our research, though long-term ability of the community to resist tree invasion was not evaluated during the relatively short life of this project. Herbaceous communities on poor soils (specifically, little bluestem meadows) also had high net resistance to tree invasion. The communities with the lowest resistance to invasion were herbaceous communities ori productive soils. These herbaceous communities on--

good soils often represent very early stages of old field succession, and are undergoing rapid colonization by shrubs. ' :

Study Name: Tree growth retardants. '

Results:

Six TGRs were identified as the major compounds that have been used in utility situations, including maleic hydrazide (Slow Grow), dikegulac sodium (Atrinal), chlorflurenol (CF125 or Maintain A),

paclobutrazol (Clipper), flurprimidol (Cutless), and uniconazole (Prunit). Dikegulac, maleic'hydrazide, and chlorflurenol affect cell division and block apical dominance, restricting terminal growth. ::

Paclobutrazol, flurprimidol, and uniconazole are anti-gibberellic in nature; they allow cell division and growth to occur but suppress cell wall and intemodal elongation. The advantages and disadvantages and method of application and use of the various TGRs were considered. TGRs; like other vegetation management tools, do not meet all of the vegetation management needs, but can be integrated into a comprehensive vegetation management program.

a-Page 7 of 11 Study Name: ROW herbicide buffer zone efficacy.

Results:

No buffer or 10 ft buffers were sufficient in protecting water quality where medium to low density vegetation was treated with herbicide. Larger buffer zones were needed where high density vegetation was treated; buffers of 25 ft or more achieve stream water quality criteria. Positive water samples contained concentrations of herbicide of 0.001 to 0.002 mgA with the highest at .006 mgIl, levels not harmful to humans or aquatic life.

Study Name: ROW natural growth Inhibitors.

Results:

The annotated bibliography highlighted literature pertinent to natural growth inhibitors, including a broad overview of the subject of allelopathy, microorganisms, and tree pathogens. The literature reported approximately 200 phytotoxins from over 100 microbial species, most being produced by, fungi. A few of the phytotoxins described in the literature have already been developed as commercial.

herbicides (e.g., bialaphos and phosphinothricin-the synthetic version is the herbicide Glufosinate).

The development of herbicides from microbially produced phytotoxins is a highly promising area for future discovery, which has'not been adequately explored. Literature regarding phytotoxins isolated from pathogens of trees is very limited, and those that have been reported were toxic only to the host plant and show little promise as a herbicide/growth regulator for a broad range of trees. Articles pertaining to allelopathic effects of one plant on another were also reviewed. Very few investigations of allelopathy found in the scientific literature stood up to the scrutity of proof required to 'prove*

allelopathic effects of one plant on another.

Study Name: - Volney-Marcy Rubus study.

Results:

Rubus allegheniensis Porter (common blackberry) was the dominant Rubus species on a recently cleared ROW in Upstate New York. The presence of Rubus was not affected by first maintenance cycle treatments. In response to second maintenance cycle treatments, basal schemes generally had more Rubus than stem-foliar treatments. In terms of broad plant community stability on ROWs, the role of Rubus is unclear, as are the implications of any differences in Rubus cover among treatments with regard to multiple uses of ROWs.

Principles and practices of vegetation management on electric power Project Name: transmission line 'rights-of-way.

Results:

During initial ROW clearing the number of desirable plants was reduced with herbicide treatment, undesirable plants were generally the same between herbicide-treated and no herbicide treatment plots, and costs were higher for herbicide treatments as compared with no herbicide treatment. The most cost-effective method for initial clearing was clear or selective cutting with no herbicide treatment. During the first conversion cycle there was equal reduction of undesirable vegetation and maintenance of desirable vegetation. Therefore, cost-effectiveness was based on treatment costs alone' Basal treatment costs were nearly double that of stem-foliaf with the nonselective mode being less costly than selective; therefore, the nonselective stem-foliar treatment was the most cost-effective scheme. For the second conversion cycle there were more' desirable plants with the selective mode, there was a greater reduction in'undesirable plants with stem-foliar schemes, and basal treatment costs were nearly double that of stem-foliar. Therefore, selective stem-foliar was the most cost-effective herbicide scheme.

Page 8 of 11 A 15-year appraisal of plant dynamics on electric power rights-of-Studyame: -way In New York State.

Results:

Results from the 15-year appraisal indicated that on corridors where trees were periodically, selectively removed using herbicides, tree populations were observed at constant low density. There was a spatial redistribution'of trees in 1991 compared to 1975, with fewer trees fri the cdriidor centerline and more in the border areas along conidor edges in 1991. 'An increase in tree density was observed on corridors that did not receive' herbicide treatments to control trees, but had only aboveground portions of trees selectively removed using'periodic hand cutting. Species composition generally did not change over the study period. Acer, Betula, Fraxinus, Populus, Prunus,and Quercus species were commonly present on all sites during 1975 and 1991. Red maple (Acerrubrum L.) and '

white ash (Fraxinus americana L.) were ubiquitous. Operational, selective removal of trees on powerline corridors with herbicides, whereby both the above- and below ground portions of the plants are periodically killed and site disturbance minimized, can lead to the creation of relatively stable,--

compositionally constant, low density tree populations.

Cost effectiveness of herbicide and non-herbicide alternatives for Study Name: vegetation management on powerline corridors in the northeastern

-.United States: A review. -

Results:

The maintenance of vegetation on electric utility rights-of-way is a dynamic process affected by site conditions, public interest, environmental concerns, and costs. Existing information is insufficient to identify one method or group of methods as optimal in all circumstances. Long-term, cost-effective management of ROW vegetation is dependent upon both herbicide and non-herbicide methods. A prescription-based approach, where different methods are selected for different circumstances, is the most rational strategy. To effectively manage this type of program, it is essential that utilities have well-trained professionals and data to make operational prescriptions in the field.

Study Name: Utility right-of-way vegetation management in Kamer blue butterfly StudyName.habitat areas.

Results: . - '-'

Increased relative light level was the primary variable associated with increased blue lupine abundance. Percent cover of blue lupine was correlated positively with both the recent and longer-term use of herbicides. Blue lupine clump density was most dependent on relative light intensity, and:

was negatively associated with the number of years since the last management activity and the recent use of herbicides.

Volney-Marcy electric transmission line vegetation management je T project: Third cycle treatments Results: -; B .

See individual study descriptions.

References:

See individual study descriptions.

a-Page 9 of 11 Long-term effectiveness of various herbicide and non-herbicide Study Name: treatment schemes during the second conversion cycle.

Results:

Over an 11-year period,stem densities were maintained at low levels using selective chemical treatments in an IVM program on the Volney-Marcy powerline ROW in Upstate New York. Larger trees on the ROW were dominated by gray birch, whereas red maple was the dominant species for smaller seedlings, suggesting that a species shift in undesirable species may be occurring on the Volney-Marcy ROW. Mechanical treatments resulted in higher undesirable densities than chemical treatments. Desirable stem densities have increased or remained constant over time with an IVM approach.

Study Name: Effectiveness of various selective herbicide treatment schemes to StudyName:reclaim a ROW.

Results:

Pending.

Vascular plant species diversity before and after first maintenance Study Name: cycle vegetation management.

Results:

Pending.

Study Name: Competitive hierarchies of desirable plant communities.

Results:

Pending.

Study Name: Herbicide deposition patterns for commonly used treatment schemes.

Results:

Pending.

Study Name: Site-specific and landscape-level effects of ROW vegetation management on songbird communities.

Results:

There was a difference in shrub density on the two powerlines; the older Fitzpatrick-Edic line, with a history of mechanical treatments, had a higher shrub density than the younger Volney-Marcy powerline. There were two times more bird territories and nests in high shrub density areas.

Songbirds respond directly to shrub habitat on ROWs; as shrub density increases, shrub nesting birds increase. Once established, the permanence of the plant community produced with selective herbicides may be better for short-lived bird species than the regular destruction of the plant community required in mechanical treatments.

Page 10 of 11 Study Name: A study of the Invasion and growth patterns of Betula popullfslia Marsh. (gray birch) on a powerline ROW In New York State.

Results:

Gray birch tree heights ranged to over 11. m and tree ages from 4 to 13 years. Most of the trees were established within 3 years after treatment. Young powerline corridors that have mesic to hydric moisture regimes are well-suited to'birch invasion, particularly with management-related disturbance.

Minimizing site disturbance and promoting the development of a tall shrub community should reduce birch presence on older powerlines.

Effectiveness of various herbicide treatment schemes on ROWs that Study Name: were operationally treated during the last treatment cycle.

Results:

Pending Herbicide dannsition natterns fMr rcnmmnnsv iseri treatment schegmes-Study Name: - Impacts on community structure and composition in the near- and long-* -,

term.

Results:

Pending Study Name: Expanding the treatment window for cut stump herbicide treatments.

Results:

Pending Study Name: Effectiveness of mowing to reclaim a previously mowed ROW.

Results:

Pending Study Name: Demonstration of ROW Vegetation Management Tools on a ROW near Albany, New York.

Results:

Vegetation management treatments were demonstrated at the site for the Environmental stewardship of utility rights-of-way conference held in Albany, NY in June 12-13, 2001. The event was hosted by Niagara Mohawk Power Corporation, Energy Alliance of New York, and the State University of New York College of Environmental Science and Forestry (SUNY-ESF). The workshop participants included professionals from the utility industry, regulatory agencies, environmental analysts, and universites. Presentations were made by the ulities: NMPC, New York Power Authority, and New York State Electric and Gas. The agency perspective was presented by the New York State Department of Environmental Conservation and the Public Service Commission. SUNY-ESF presented a review of current research and a new framework in which to think about Integrated Vegetation Management

a-Page 11 of 11 Project

Title:

Shrub community dynamics on a powerline corridor in upstate New Projct Ttle:York.

Results:

See individual study descriptions.

Study Name: Select shrub life histories: An annotated bibliography.

Results:

Synopsis pending.

Factors influencing the distribution and abundance of shrubs on ROWs Study Name: in New York State: An observational study.

Results:

Pending.

Assessment of cultural treatments to increase and maintain the Study Name: presence of desirable shrub communities: A manipulative field experiment Results:

Pending.

Vegetation dynamics on operationally treated powerline corridors Study Name: across New York state: 25-year re-assessment of Niagara Mohawk lines.

Results:

Pending.

Project Name: Partnerships for powerline vegetation management In New York.

Results:

Pending.

APPENDIX 5 701 P~nnsylvflma Aver.ue NW11, Was.,iir.;on 0 C.20004-2566 ee~e202-508300 Nk- EDISON ELECTRIC a Di Wem INSTITUTE ENVIRONMENTAL.

STEWARDSHIP.STRATEGY FOR' ELECTRIC UTILITY.'

-'RIG'HTS-OF-WAY'.

FORWARD This strategy was approved by the Edision Electric Institute's Vegetation Management Task Force (VMTF) on August 12, 1996. The VMTF prepared this strategy in accordazice with its commitment to the Pesticide Environmental Stewardship Program (PESP). PESP is a voluntary partnership between pesticide users and three Federal agencies: the Environmental Protection Agency, the Department of Agriculture and the Food and Drug Administration. The goal of PESP is to reduce pesticide risk and to promote Integrated Pest Management programs.

For further information on this strategy contact:

Mr. Lynn Grayson Mr. Rick Johnstone American Electric Power Delmarva Power P. 0. Box 2021 P. O. Box 1739 Roanoke, VA 24022 Salisbury, MD 21801 Mr. Joel Mazelis, Manager Environmental Programs Edison Electric Institute

VEGETATION MANAGEMENT ON RIGHTS-OF-WAY' Electric utilities are charged by state and federal regulatory agencies with the responsibility for pro'viding'safe, reliable electric service to their customers. Customers may include homeowners, businesses, municipalities anid othe'rutilities. Electricity is a product which is needed on" demand and cannot be stored inlarge quanitities. Because it is essential for domestic use, economic growth and providing vital services, the pathways for the flow of electricity must be kept'open at all times.

Trees and other vegetation can cause interruptions of service by growing into, or falling through power lines. These interruptions are a major concern of electric 'utilities because

.service is not being provided to customers when needed. A loss of service is not only costly and inconvenient to customers - it can also be life-threatening to people on life support systems. For many utilities, tree related outages rank among the leading 'cau'ses of interruptions of electric service during both normal operating conditions and during major storm events.

Properly maintained rights-of- way are essential to provide safety for' customers and workers, minimize tree-related outages, provide access for inspection and fmiaintenance of facilities and for timely restoration of service during emergency conditions.

The goal of right-of-way vegetation management programs is to provide safe transmission and distribution service and to minimize interruptions caused by trees and other vegetation while maintaining a harmonious relationship 'Withvaried'land uses and the environiment.

Most electric utilities employ a combination of control methods for' right-of-way vegetation management in a'process known as "Integrated Pest Management" (IPM).

Integrated pest management is'a system oficontrolling pests (wveeds, diseases, insects or others) in which pests are identified, action thresholds are considered, al! possible control options are evaluated and selected control(s) are' implemiented. Control option's - which include biological, chemical, cultural, manual and mechanical methods - 'are used' to prevent or remedy unacceptable pest activity or damage. Choice of control option(s) is based on effectiveness, environmental impact,- site characteristics, worker/public health and safety and economics. The goal of an [PM system is to manage pests and the environment to balance benefits of control, costs, public 'health and environmental quality. ' ',

In vcgetation management, pest' rclers to trecs' and other vcgetation which arc capablekorcndangering the sarety or the public and workers and the reliability orservice or the lines.' '

As part of their IPM Program, nearly all utilities utilize some mechanical vegetation control. However, cutting or mowing vegetation perpetuates the growth of incompatible (tall growth) vegetation because of the biological response of sprouting. When a single stem is cut, multiple sprouts can grow from the severed stump or the root system (so-called "root suckering"). These sprouts are fast-growing because they are fed from the root system which is already well established. A repetitive cycle of cutting and sprouting results in'an increasing density of tall growth species.

It is a common public belief that mechanical/manual methods (power saws and mowing) are safer and have less environmental impact than herbicide me'thods. Often overlooked are environmental and safety concerns associated with repeated cutting of vegetation such as: soil corn paction from heavy equipment, damagirig sensitive wetland areas, worker and environmental exposure to petroleum products (which are more toxic than many herbicides used for R/W maintenance), the potential for physical injury from sharp tools and equipment and the repeated, significant alteration of potential wildlife habitat.

In many instances, herbicides are preferred because they control the entire plant and greatly inhibit re-sprouting, thereby reducing the need for repetitive cutting. Even though most herbicides used for vegetation control have low human and animal toxicity, some utilities minimize herbicide use because they fear adverse public reaction from the use of synthetic herbicides. Improved environmental safety of available products and technology and the potential for increased competition in the utility industry may result in increased herbicide usage.

The long-term goal of a vegetation management program is to provide for public and worker safety and to provide reliability of service by converting right-of-way, plant communities from predominately tall growing plant species to communities dominated by low growth plant species. This can be accomplished by selectively controlling tall growing plant species, while preserving low growing grasses, herbs and woody shrubs over a period of many years. With proper management, the lowv growing vegetation can eventually dominate the right-of-way and' retard the growth of the tall growing vegetation, providing control of incompatible vegetation and reducing the need for future treatments.

PESTICIDE USE AND RISK REDUCTION Most industrial herbicides used for vegetation control in rights-of-way arc very low in toxicity; in fact, much lower than the petroleum products necessary to power the equipment used for cutting brush. Therefore, the use/risk reduction strategy for electric utilities is aimed at minimizing the amount of active ingredient of a particular product (or products) per acre rather than reducing the total volume of products used. Lower use per acre is both environmentally responsible and economical: by utilizing only the amount necessary to control vegetation, risks arc minimized and material costs arc reduced.

2

Most initial right-of-way vegetation applications are made using non-selective techniques. Non-selective applications are also utilized for maintenance where brush heights and/or densities are high; Mechanized applicators are'frequently 'used'for these applications.'

In subsequent applications or in applications where brush heights'and densities are low to moderate, low volume foliage or basal applications are generally utilized. Carriers for low volume applications are normally water for foliage treatments while syrithetic or natural penetrants are used for basal treatments. These applications are referred to as "low volume" because of the lower-quantities of water or penetrants utsed to' dilute and carry the'chemicals to the plant. Low volume techniques employ garden-type hand-pump or motorized applicators to apply the herbicide mixture at very low rates arid pressures.

The key to reducing the amount of herbicide applied per acre is the use of selective applications; i.e., treating only those;plants that are capable of growing' tall 'enough to threaten power lines and to leave low growth plants (shrubs,' herbs,:'grasses) untreated.

This can be accomplished with any ground application method, but the 'selective- nature of the treatment remains the same. As a result, active ingredients of herbicide applied per acre are minimized and risks are reduced.

Selective applications can also result in reduced herbicide usage as a 'result of species composition changes from incompatible plant species to compatible plant species.

Future herbicide treatments to the same areas will require lesser amounts of Ifeibicides due to the selective nature of the application combined with fewver target stems.

The use of non-active adjuvanrts &'n' als'o contribute to reduced volume and, therefore, risk. Adjuvants can improve efficacy and adherence to the target plants resulting in less material being required for control, less runoff from the plant leaf surface and reduced potential for volatilization.

During applications the potential for exposure is only to the diluted herbicide mixture and that exposure is brief sincev-workers apply the solution and then leave the area. After the herbicide is absorbed by the plani, direct'exposure is virtually negligible. Any herbicide not absorbed by the plant is rapidly biodegraded by micro-organisms or light.

Considering the low toxicity, rapid uptake and rapid :biodegradation of most'modem herbicides, re-entry times are not signifkant for these types of application.

3

CURRENT RESEARCH The electric utility industry cooperates with manufacturers, applicators, regulators and educational institutions to field test and develop safe and effective herbicide products and application equipment. Research into improved technology is an on-going process.

Included in this research are efforts to reduce worker exposure to herbicide concentrates during mixing and to reduce environmental risks associated with the disposal of containers.

Biological controls are being researched to strengthen this phase of Integrated Pest Management methods. For example, researchers have identified vegetative cover that impedes the invasion of incompatible tree species through allelopathy. Such research could lead to the development of biopesticides for use in R/W maintenance programs.

Also being studied are the application techniques and materials that are most effective in producing compatible cover types that are capable of competing for growing space in rights-of-way. Promoting similar cover types on the rights-of-way through selective herbicide applications can reduce the need for maintenance, thus reducing risk and use in the long term.

The electric utility industry will continue to support research that is based on scientifically sound risk reduction principles which benefits the environment, their customers and their employees.

1ARRIERS TO ADOPTIO[N There are both internal and external barriers to the adoption of a use and risk reduction strategy. For example, internally, few educational pesticide stewardship programs that are specifically geared to R/W maintenance have been developed. External barriers exist because much of the public is unfamiliar with herbicides and, therefore, may not understand their use. They may be unaware of the rigorous toxicological and environmental testing that is required by the U. S. Environmental Protection Agency (USEPA) prior to registration of herbicide products. In addition, many people are unaware of the safety and environmental risks involved *in other right-of-way maintenance activities; therefore, it is difficult for them to make a knowledgeable comparison of the various options available. This lack of understanding creates a knowledge barrier ror the public.

I 4

STEPS TO AID IN ADOPTION OF STRATEGY As a result of the internal and external ba'rriers, some utilities 'may' be reluctant to adopt new technuology or follow industry standards.- One'effective method to induce utilities to adopt these technologies would be to produce a training video promrotinrg pesticide stewardship that has received the endorsement of both the electric utility industry and the USEPA. The video could be shownvat 'regi6nal association ffieetings. On a national basis, the Edison Electric Institute has the potential to reach' inuch of the electric utility industry'through meetings and seminars.

As part of a policy statement regarding IPM Programs, the USEPA' and state regulatory agencies should support risk reduction through the use of improved materials and technologies which are based on scientifically verified'informiation. The utilities who utilize these materials and technologies could then be recognized:by regulatory agencies for their efforts. This would encourage'other utilities and would reassure the public about electric utilities' vegetation management programs.

An outreach program should be produced to educate the general public regarding utility safety and reliability concerns.'The' program' should also address the IPM approach to R/W maintenance and the Best Management Practices that are a part of this strategy.

RIGHT-OF-WAY VEGETATION MANAGEMENT STRATEGY The purpose of this strategy is to p'rovide principles for current and future 'vegetation managers that will minimize overall risk to people and the environment whilc'providing safe and reliable electric service. The strategy is- designed to protect wildlife, groundwater, surface water, soils, utility customers, utility workers and the general public. The objectives of this strategy are:

That program prescriptions will be selected which balance environmental concerns, public needs, safety and cost effectiveness.

That utilities will use Integrated Pest Managemient methods that are supported through scientific research as minimizing risk and increasing effectiveness for use in right-of-way vegetation management programs.

That'utilities will 'adopt Best Manageriient 'Practices (BMPs) for herbicide applications. These practices will be based on the latest scientific research among utilities, manufacturers, applicators, regulators and universities.

. 5 I

That utilities will set as a long term goal of vegetation management programs the reduction of the level of active ingredient per unit of land area. This is to be accomplished through the proper selection and use of application methods, equipment and technology which will promote and facilitate minimal application rates. Use records for each utility can be used to track application rates.

That utilities, will. support research. and development initiatives for reduced risk pesticides and for improved herbicide handling (storage, transport, mixing and application) that leads to improved worker protection. The utilities will, where available, adopt those developments that are proven to reduce risk and are cost effective.

That utilities will encourage the accelerated approval of any risk reduction recommendations to be included on the labels of herbicides used for vegetation control. Utilities will encourage the streamlining of the regulatory process in order to minimize the manufacturer's costs of relabeling.

BEST MANAGEMENT PRACTICES Best Management Practices (BMPs) are included in this strategy to assist in the planning and implementation of ground application programs. They are intended to supplement and not replace the herbicide labels. The practices should be used when the Integrated Pest Management control option indicates that herbicide applications are appropriate.

The BMPs will ensure that practical measures arc being taken to reduce pesticide use and risk in order to meet the objectives of the pesticide stewardship strategy.

1. The following factors should be considered in the planning of any herbicide application:

- Target species

- Height and density of vegetation

- Land use: within and adjacent to the right-of-way

- Label restrictions

- Natural and man-made restrictions

2. Follow herbicide label directions and any other supplemental label information provided by the manufacturer. Material Safety and Data Sheets should also be reviewed.

6

3. Only herbicides registered by the U. S. Environmental Protection Agency and the designated responsible state agency shall be used.

4. All herbicide applications shall be performed by applicators who are qualified in accordance with the laws and regulations of appropriate regulatory agencies.

5. Selective application techniques should be used wherever practical so that compatible vegetation is not treated.

6. Where practical, herbicides should be measured and mixed with diluent prior to transfer to application site.

7. Herbicide containers must be reused, recycled or otherwise disposed of in a proper manner.

8. Where practical, transfer of herbicide mixtures should be made directly from shipping containers to holding tank and/or application equipment through closed transfer systems, where possible.

9. Appropriate techniques should be used to avoid significant off-target drift.

10. These special precautions should bc observed during periods of inclement weather:

- Applications should not bc made in, immcdiately prior to, or immediately following rain wbhcn runoff could be expectcd.

-Applications should not be made wlhcn wind and/or fog conditions have the potential to cause drift.

- Basal bark applications should not bc made when stemis arc wet with rain, snow or ice.

11. When making applications near watcr, crops, and/or other restrictions, application personnel should put their backs to the restricted area with the treatment being directed away from the restricted arca.

/9 7

APPENDIX 6 Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF.WAY IPP Ctr P.R.I KV Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 CAPITAL REGION Alps - Berkshire 912264 345 234.6 sch 2001 234.6 Edic - New Scotland 912339 345 845.7 845.7 Leeds - Pleasant Valley 912345 345 1031.7 1031.7 New Scotland - Alps 912333 345 533.8 sch 2001 533.6 New Scotland- Leeds 912304 345 681.7 661.7 Reynolds Rd - Alps 912344 345 224.4 sch 2001 224.4 West Sand Lk Tap Included Porter - Rotterdam 912104 230 210.9 96 - 97 210.9 Rotterdam - Bear Swamp 912305 230 786.0 1999 788.0 tlnora Tap Included 0.0.

Front St Tap Included 0.0 Rosa Rd Tap, Included 0.0 GE R&D Tap - Included- 0.0 Go Silicon Tap Included 0.0 Prospect Hill Tap Included 0.0 Albany - Greenbush 912265- 115 21.9 21.9 Atlantic Cam - Pleasant Val 912067 115 101.9 101.9 Independent Cement Tap included 0.0 Churchtown . Pleasant Val 912242 115 400.8 p 1999 400.8 Blue Stores Tap Included 0.0 Greenbush - Churchtown 912065, 115 317.6 317.6 Castleton Tap Included 34.5 0.0 Brown Co Tap Included, 34.5 0.0 Hudson Tap included 0.0 Valkin Tap Included 0.0 Independent Cement Tap included 0.0 ADM Milling Tap included 0.0 Ft Orange Tap. Included 0.0 Greenbush - Stephentown 912222 115 67.4 sch 2001 67.4 Grooms - Inman Rd 912338 115 52.4 52.4 Grooms - Johnson 912321 115 41.5 41.5

, t

. Cycle . 2 ...t ROW Cycle 5 2001 to 08 Page I 12119/2001

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF.WAY IPP Ctr P.R. # KV Acres Tress 2001 2002 2003 2004 2005 2008 2007 2008 Hoosick- Bennington 912301 115 37.1 97 37.1 Johnson - Maplewood 912023 115 24.1 24.1 Krurnkill - Albany 912331 115 common (se,Patoon- Alanyl Maplewood - Menands 912157 115 49.8 49.8 A.L. Tech Tap included 0.0 Watervaliet Arsenal Tap included 0.0 Menands - Reynolds Rd 912057 115 21.0 21.0 Rensslear Waste Tap Included 0.0 Menands - Riverside 912334 115 22.8 22.6 Albany Waste Treat Tap included 0.0 New Scotland - Reynolds Rd 912318 115 207.3 98 207.3 North Troy - Hoosick 912295 115 38.8 38.8 North Troy - Reynolds Rd 912302 115 160.0 6ch 2001 160.0 Scaway Tap 0.0 Patroon - Albany 912330 115 67.4 67.4 Star Textile Tap Included 34.5 0.0 Westmere Tap Included 34.5 0.0 McKnownville Tap included 0.0 Ohau - Shalon Tap Included 0.0 Reynolds Rd - Greenbush 912292 115 common ISee Nw Scott"nd - RsYftl Included Riverside - Reynolds Rd 912323 115 24.4 24.4 Rotterdam - Albany 91226B 115 188.4 188.4 Depot Rd Tap included 34.5 0.0 Atlas Copco Tap included 34.5 0.0 Union Sta Tap included 0.0 Air Products Tap included 0.0 Rotterdarn - GE 912128 115 19.7 19.7 Rotterdarn New Scotland 912305 115 55.3 98 55.3 Rotterdan - Woodlawn 912021 115 198.9 198.9 ROW Cyce 5 2001 to 08 Page 2 12V19/2001 r

Transmission Right-of-way Management Program - Master Bnush Danger P.R. #- KV Acres., Trees 2001 2002 2003 2004 2005 2008 2007 2008 RIGHT-OF-WAY IPP Ctr Burdock St Tap Included 0.0 Included 0.0 GE Insulating Tap included Lynn/Christer Ave Tap% Included 0.0 WeaverlCrmpbell St Taps Included 0.0 Watt St Tap included 0.0 Tobins Packing Tap Included 0.0 Curry Rd Tap included 0.0*

Spier . No Tray 912035 115 98.0 97 - 98 98.8 Schaughticoke Tap Included 0.0 0.0. 101.5 Spier - Rotterdam 912020 115 101.5 97 - 98 Swaggerstown Tap Included 0.0 ..

Stoner - Rotterdam 912247 115 55.9 97-98 55-9 Trinity - Albany 912335 115 14.0 t4.0 Seaboard Allied Milling Included . 0.0 Corp Tap Included 0.0 115 105.1 1999 105.1 Unlonville - Atlantic Cam 912019 Owens Corning Tap Included 0.0 GE Plastics Tap Included 0.0 Callahan Tap Included 0.0 Atlantic Cerment Tap included C 0.0 Alrco Tap Included 0.0, 912235 115 103.5 103.5 Woodlawn - Menands Everett Rd Tap Included 0.0 Central Ave Tap Included 0.0 State Campus Tap Included 0.0 Patroon Tap Included 0.0 Ruth Rd Tap, Included 0.0 63.1 Woodlawn - Pinebush 912022 115 63.1 e9 78,5 78.5 Amsterdam - Rotterdam 912016 Glenville Pump Tap included 0.0 69 58.1 56.1 Rotterdam - Schoharie 912178 1999 79.2 79.2 Ballston - Mechanicville 912008 34.5 5 79.2 Curtis Sawmill Tap. Included 0.0 47.7 Ballston - Rosa Rd 912074 34.5 7 47.7

, Agawam Tap Included 0.0 Included . 0.0 GE Training Tap 1211912001 Page 3 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. S KV Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 Bethlehem - Rensseleu 91227f 34.5 5 8.1 B.1 Bethelem - Selkirk 912135 34.5 5 14.4 98 14.4 14.4 Penn Central Tap Included 0.0 Charlton - Ballston 912180 34.5 5 22.0 to be removed to be removed Colvin - Partridge 912219 34.5 5nowon912218 Colvin Plaza Tap included 0.0 Packing Co Tap Included 0.0 Quality Inn Tap Included 0.0 Commerce Ave Tap included 0.0 Cresent - School St 912107 34.5 5 7.4 7.4 Delaware - Bethlehem 912319 34.5 5 24.9 24.9 24.9 Delmar - Bethlehem 912220 34.5 5 10.6 10.8 EBsmere Tap included 0.0 Greanbush - Hudson 912250 34.5 7 179.0 1995 99 179.0 NYSE&G Tie included 0.0 Julliard Tap included 0.0 Chatham Tap included 0.0 Johnsonville - Clay Hill 912094 34.5 7 77.7 Jct - Hoos 97 77.7 77.7 Columbia Tap included 7 11.5 97 11.5 11.5 Lydell Inc Tap included 0.0 Oak Mitsui Tap Included 0.0 Kamer - Patroon 912320 34.5 5 11.6 11.6 Albany Resourc Recovery included 0.0 Lansingbwg - 7th Ave 912272 34.5 5 2.5 2.5 Eddy Tap Included 0.0 Ubenty - Tibbetts 912313 34.5 5 1.2 1.2 Mt Ida Hydro Tap Included 0.0 Maplewood - Latham 912957 34.5 5 8.7 8.7 Colonie Tap included 0.0 Mountain View Tap Included 0.0 Maplewood - Uberly 912238 34.5 5 8.2 1999 8.2 TEK Hughes Tap Included 0.0 12119/2001 ROW Cycle 5 2001 to 08 Page 4 U

Transmission Right-of-way Management Program - Master fmnih Danger RIGHT-OF-WAY IPP Ctu P.R. N KV Acres Tress 2001 2002 2003 2004 2005 2006 2007 2008 Mechanicviife - Schaghticoke 912144 *34.5 7 35.3 35.3 35.3 Mechanicvilie- School St 912059 34.5 7 35.9 35.9 Half Moon Tap included 0.0 Cohoes Welding Tap Included 0.0 Bell Fabrication Tap Included 0.0 GE Silicon Tap Included 0.0 Grand Union Tap Included 0.0 Manands - Uberty 912043 34.5 5 28.1 28.1 Portec Inc Tap Included 0.0 Cross St Tap Included 0.0 Newtonviile - Patroon 912115 34.5 5 25.2 25.2 Lathamn Top Included 0.0 North Troy - Lansingburg 912100 34.5 5 15.2 15.2 North Troy - Tibbetts 912267 34.5 5 44.6 44.6 RPt linac Tap Included . 0.0 Brunswick Tap Included 0.0 98 Callahan Quarry Tap Included 0.0 98 Norton - Menands 912078 34.5 8 18.2 18.2 D&H Shops Tap Included 0.0 Adirondack Tap Included 0.0 Maplewood Tap Included 0.0 Maplewood-Norton* 5 Included 0.0 Patroon

Partridge 912218 34.5 5 9.8 9.8 Nuclear Sta Tap Included 0.0 Partridge.- Riverside 912298 34.5 5nowon912218 Rensselear - Greenbush 912142 34.5 7 40.4 40.4 Sterline Research Tap Included 0.0.

Winthrop Tap Included 0.0 Jelitf Corp Tap Included 0.0 Amtrak Tap Included 0.0 Rosa Rd. McClellan 912314 34.5 5 lead cable on distribution WRGO Tap included 0.0 Rosa Rd - Vishers 912130 34.5 5 15.1 15.1 Knoll Sta Tie Included : 0.0 0.0 Atomic Sta Tie Included 0.0 0.0

.t . 1- - . I (

Page 5 12/19/2001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Cit P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Rotterdamn. Scotia 912243 34.5 7 10.6 10.6 Schaghticoke - Johnsonvulle 912007 34.5 7 33.9 33.9 33.9 Johnsonville Hydro Tap included 0.0 Valley Falls Hydio Tap included 0.0 School St - Maplewood 912228 34.5 5 12.9 12.9 Newark St Tap included 0.0 Mohawk Paper Tap Included 0.0 Norlite Tap included 0.0 WATV Iron & Brass Tap included 0.0 School St - North Troy 912101 34.5 5 42.4 42.4 Watetrotd Tap included 0.0 Mohawk Paper Tap included 0.0 Corlis5 Park Tap included 0.0 Scotia - Rosa Rd 912126 34.5 5 34.7 34.7 ALCOIGE Nott St Tap included 0.0 Schenectady Sewage Tap included 0.0 COMDEC Tap included 0.0 Snyders Lk - Brainard 912212 34.5 8 47.8 47.8 Visrhers - Woodlawn 912184 34.5 7 33.6 33.6 Niskayuna Pump Tap Included 0.0 Woodlawn - Karnet 912213 34.5 7 19.8 19.6 1403.9 1212.1 879.5 1422.3 452.5 728.1 1329.1 1162.6 Page a 1211912001 ROW Cyce 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. I xV Acres Tres. 2001 2002 2003 2004 2005 2006 2007 2008 NORTHEAST REGION Edic - New Scotland 912303 345 804.5 804.5 Porter - Rotterdam 912104 230 418.5 96 418.5 Adirondack 115 912048 115 270.7 270.7 Warrensburg - North Creek 912052 34.5 85.5 85.5 Canaloharie - Marshville 912289 115 9.7 9.7 Inghams - Colliers 912033 115 101.5 1999 101.5 Beardslee Tap Included 0.0 Inghams - St Johnsville 912027 115 36.9 36.9 Ingliams -Stoner - 912070, 115 193i 193.7 Clinton Tap Included, 0.0 Meco Tap & Included 0.0' 1 999 Center Si Tap Included 0.0 Spier E.J. West 912080 its 303.9 1997. 98.99 309.9 International Paper tap Included 0.0 Stewart's Bridge Tap Included 0.0 Warrensburg Tap Included 0.0 HadleyV: Luzerne Included 0.0 Spler - North Troy 912035 115 291.6 1997. 98, 99 27e.2 (Spier-Mohicen section)

(Mohican-N.Troy section)

Scott Paper Tap Includead 0.0 Fort Miller Tap Included 0.0 Hollingsworth & Voss Tap Included 0.0 Thompson Tap Included 0.0 Clark Mills Tap Included 0.0 Battenkill Tap Included 0.0 Searles Tap Included 0.0 Spler - Queensbury 91231i 115 125.9 125.9 Sherman Is Tap Included 0.0 Ogden Brook Tap Included 0.0 Spler - Rotterdam 912020 115 469.2 1999 469.2 Brook Rd Tap included 0.0 Welbel Tap Included 0.0 West Milton Tap included I 0.0 Page 9 12119/2001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R # KV Aries Tres 2001 2002 2003 2004 2006 2006 2007 2008 Ballston Tap included 0.0 Malta Tap Included 0.0 St Johnsville Marshville 912322 115 34.9 34.9 Stoner - Rotterdam 912247 115 180.8 180.8 Vails Mills Tap included 0.0 Church St Tap included 0.0 Amsterdam Tap Included 0.0 Ticonderoga - Republic 912073 115 197.1 197.1 Hague Tap included 0.0 International Paper Tap included 0.0 Crown Point Tap Included 0.0 Whitney St Tap included 0.0 Port Henry Tap included 0.0 Whitehall - Mohican 912051 115 212.5 1999 212.5 (Mohican-twr 104)

(Twr 104 - Whitehall)

Adirondack Res. Recovery included 0.0 Finch Pruyn Tap Included 0.0 Glens Falls Cement Tap included 0.0 Burgoyne Tap Included 0.0 Peckharn Materials Tap Included 0.0 Great Meadows Tap Included 0.0 Comstock Tap INYSE&G) included 0.0 Cornstock Tap Included 0.0 Whitehall - Queensbury 912297 115 33.9 33.9 Whitehall - Rutland 912296 115 5B.7 56.7 Whitehall - Ticonderoga 912072 115 175.9 sch 2001 175.9 Amsterdam - Ephratah 912069 69 152.3 152.3 Market Hill Tap included 0.0 Mohasco Mills Tap Included 0.0 Mohasco Tap included 0.0 Tribes Hills Tap Included 0.0 Johnstown Tap & included 0.0 Johnstown - Meco included 0.0 Amsterdam - Rotterdam 912018 69 4.4 4.4 Cobleskiil - Schoharie 912178 69 49.7 49.7 Portland Cement Tap included ' 0.0 ROW Cycle 5 2001 to 08 Page 10 12119/2001

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Cobleskill - Summit 912133 89 20.8 20.8 Cobleskill Ag & Tech Tap Included 0.0 Richmondville Tap Included 0.0 Gloversville - Canajoharie 912290 69 101.9 101.9 Gloversville - Meco 912141 69 16.4 18.4 Marshville - Cobleskill 912317 69 85.3 85.3 Mayfield - Northville 912089 69 63.9 83.9 Mayfield - Vails Mills 912340 69 42.8 42.6 Meco -,Mayfield 912108 69 116.1 1999 116.1 MCA Tap included 0.0 Hill St &Gloversville Taps Included 0.0, Schoharie- Rotterdam 912176 69 119.8 119.8 Middleburg Tap included 0.0 Delanson Tap Included. 0.0 Ashley - Glens Falls 912140 34.5 9.0 1999 9.0 Ceiba-Geigy Top included 0.0 Glens Falls Wastewater I11 Included 0.0 Glens Falls Wastewater (2) included 0.0 Baliston - Mechanicville 912008 34.5 Capital Ballston - Rosa Rd 912074 34.5 Common 1999 Cambridge - Hoosick 912904 34.5 28.7 28.7 Union St Tap . Included 0.0 Chariton - Ballston 912180 34.5 54.9 54.9 West Milton Top, Included 0.0 1999 Chestertown - Schroon Lk 912109 34.5 125.6 s 1999 125.8 Pottersville Tap Included 0.0 Fort Gage - Warrensburg 912049 34.5 7 88.3 8d.9 Bolton Tap Included 55.7 1999 Glens Falls - Bay St 912098 34.5 10.0 10.0 Page 11 1211912001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. I KV Acres Trees 2001 2002 2003 2004 2006 2006 2007 2008 Glens Fails - Mohican 11 912028 34.5 35.2 35.2 Nibco Tap included 0.0 Glens Falls - Mohican # 12 912232 34.5 1.3 1.3 Henry St - Glens Falls 912029 34.5 7.0 7.0 South Glens Fails Tap included 0.0 Crown Zellarbach Tap included 0.0 Hudson

McCrea 912271 34.5 see 912028 N.E. Recycling Tap included 0.0 (Sagarnue) included 0.0 Decora Tap included 0.0 Middle Falls I I 912145 34.5 5.1 5.1 (Stevens & Thompson) included 0.0 Middle Falls - Cambridge 912056 34.5 54.5 54.5 Battenkill Tap included 0.0 Hollingsworth & Voss Tap included 0.0 Biotech Tap included 0.0 Greenwich Tap included 0.0 Middle Falls - Schuylervidle 912097 34.5 22.8 22.8 Victory Mills Hydro Tap included 0.0 Mohican - Hudson Falls 912233 34.5 4.3 4.3 Turrelt Tap included 0.0 Mohican - Adirondack 912312 34.5 8 10.5 10.5 Chase Bag Tap included 0.0 GE (John St) Tap included 0.0 Sandy HiU Tap Included 0.0 Moreau - Baker Falls Included 0.0 North Creek - Indian Lk 912294 34.5 238.3 sch 2001 238.3 Barton Mines Tap (1) included 0.0 Gore Mtn Tap included 0.0 Barton Mines Tap (21 included 0.0 Barton Mines(Hudson RI Tap included 0.0 North River Tap included 0.0 Oueensbury - Bay St 912287 34.5 4.4 4.4 Queensbury - Fort Gage 912216 34.5 51.0 51.0 Oueensbury - Henry St 912310 34.5 37.8 1999 37.8 ROW Cycle 5 2001 to 08 Page 12 12/1912001 r

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. S KV Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 Feeder Dam Tap Included 0.0 Spler - Ballston 912003 34.5 202.1 ' 202.1 Wilton Tap Included 0.0 Saratoga Tap included 0.0 Saratoga Pump Tap included 0.0 Saratoga Knit Mills Tap Included 0.0 Skidmore Tap Included 0.0 Brook Rd Tap Included 0.0 Palette Stone Tap Included 0.0 South St Tap 1 Included 0.0 Co. Quad Graphics included 0.0 Bull Metal Container Included 0.0 General Foods Tap Included 0.0 Saratoga Industiris Top Included 0.0 Cottrell Paper Tap Included 0.0 Rock City Falls Tap Included 0.0 Spier - Glens Falls 912026 34.5 83.9 1999 83.9 Ephratah - Caroga 912175 23 73.0 1999, 00 73.0 Marshville - Cherry Vafley 912139 23 32.1 32.1 Shiron Springs Tap- Included

, ., 4 Northville - Wells 912099 23 120.3 120.3 Schenevus - Summit 912347 23 69.7 69.7 Wells - Gilmantown 912172 23 76.0 76.0 1,223.0 371.0 793.4 921.6 1,116.4 677.6 450.1 656.3 ROW's that have been retired Ashley - Truthville 912045 34.5 Spier - Hadley 912041 34.5 Corinth Tap Included Central Bridge 12 912131 23 (Central Bridge-Cavem Rd) Included Central Bridge - Schoharle 912132 23 Schoharle Stone Tap Included Page 13 12/19/2001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. # KV Acres Times 2001 2002 2003 2004 2006 2006 2007 2008 MOHAWK REGION Edrc - New Scotland 812050 345 604.0 604.0 '

Volney - Marcy 812058 345 756.1 75B.1 Adirondack - Porter 812002 230 697.0 2001 sch 697.0 Edic - Porter 812001 230 2.4 2.4 Porter - Rotterdam 812004 230 240.3 walkdown 240.3 Boonville - Porter 812101 115 100.5 spots 100.5 Boonville Mine Tap included 0.0 Stittvile Tap Included 0.0 Boonville - Rome 812134 115 147.2 2000 - 01 147.2 Ava Tap Included 0.0 Turin Tap included 0.0 Madison Tap included 0.0 Griffiss Air Base Tap included 0.0 Edic - Porter t 10 812200 115 2.9 2.9 Edic - Porter I 20 812239 115 5.7 5.7 Oneida - Cortland 812224 115 146.7 146.7 Oneida - Porter 812221 115 158.0 check .158.0 Kelsey Hayes Tap included 6.9 8.9 Yahnundasis Tap included 71.0 71.0 Oneida Ltd Tap included 13.6 13.6 Porter - Deerfield 8121B3 115 1.4 1.4 Porter - Inghams 812223 115 145.6 narrow row 145.8 Valley Tap 812165 24.2 24.2 Ilion Tap 812257 27.5 27.5 Porter - Schuyler 812164 115 15.7 15.7 Porter - Terminal 812178 115 49.3 49.3 Dunlop Tap 812180 115 0.0 812181 115 231.2 2000 - 01 231.2 Rome - Levitt Rome Cable Tap included 0.0 Page 15 12119/2001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Lehigh Tap Included 0.0 Camden Wire Tap Included 0.0 Rome - Oneida 812226 115 72.7 72.7 Teat - Oneida 812204 115 66.9 needs 66.9 Terminal - Schuyler 812126 115 55.5 needs 55.5 Yahiundashs - Chadwicks 812199 115 43.8 midspans 43.6 Special Metals Tap Included 0.0 I.1 . I......

Yahnundasis - G.E. 812154 115 40.7 40.7 Alder Ck - Old Forge 812351 46 5 154.3 on gping 154.3 ' 154.3 Boonville - Alder Ck 812325 46 7 48.1 2000 48.1 Eastern Rock Tap Included 0.0*

Deertield - Schuyier 812355 46 7 30.8e widen 30.8 '1 30.8 GE Tap, Included 0.0 Oneida City Sewage Tap Included 0.0 -

812262 46 7 45.9 1999 45.9 Deerfield - Whitesboro Kelsey Hayes Tap Included 0.0 Sauquoit Pump Tap Included 0.0 Dolgeville - Inghams 812376 48 7 11.8' 1998 11.8 New Hanford - Schuyler 812353 46 6 81.4 widen 81.4 Homogeneous Metals Tap Included 0.0 Chicago PneulSperry Rand included 0.0 46 5 121.8 on going 121.6 121.6 Old Forge - Raquette Lk 812379 1998 9.1 9.1 Pleasant - Schuyler 812342 46 5 9.1:

8123418 48 7 85.0 check 85.0 Schuyler - Valley Library Bureau Tap Included 0.0 Included W Herkimer Tap included 0.0 Mohawk MunI Tap included 0.0 Illion Tap included 0.0 Remington Arms Tap Included 0.0 Frankfort Tap Included 0.0 Union Fork & Hoe Tap Included 0.0 Frankfort Mine Tap Included 0.0 Mohawk Data Serv Tap included 0.0 12/19/2001 Page 17 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger KV Acres, Trees 2001 2002 2003 2004 2005 2006 2007 2008 RIGHT-OF-WAY. IPP Ctt P.R. I Trenton - Deelield 812341 46 7 38.6 1999 38.6 Trenton - Middleville 812349 46 7 71.1 40% in 99 71.1 Eastern Rock Tap Included 0.0 Poland Tap. Included 0.0 Trenton - Prospect 812362 46 7 19.6 1993 - 94 19.6 West Canada Tap included 0.0 Hinckley Hydro Tap included 0.0 Trenton - WNtesboro 812358 46 7 110.4 1999 110.4 Marcy Tap Included 7 0.0 widen Valley - Inghams 812372 46 7 77.3 check 77.3 Mohawk Valley Paper Tap Included 0.0 Uttle Falls Hydro Tap Included 0.0 Uttle Falls Tap included 0.0 Rock City Tap Included 0.0 46 5 14.2 check dt 14.2 14.2 Whitesboto - New Hartford 812369 Utica Cuttlry Tap Included 0.0 46 7 15.0 widen & dt 10.9 Yahnundasis - Clinton 812357 46 5 11.3 benderson 11.3 11.3 Yahnundasis - New Hartford 812370 24.6 1998 24.6 24.6 Yahnundasis - Pleasant 812364 46 5 Arnold Tap included 0.0 8endix Tap Included 0.0 812368 46 7 32.9 check 32.9 Yahnundasis - Westmoreland Clinton Tap included 0.0 812531 34.5 7 79.0 1998 79.0 Ughthousa HillCamden Voorhees Tap included 0.0 Omega Wire Tap included 0.0 788.9 1,175.8 817.1 240.6 333.8 311.9 344.0 1,157.9 1211912001 Page I18 ROW Cycle 5 2001 to OB

Transmission Right-of-way Management Program - Master Brush Dmnaet RIGHT-OF-WAY IPP Ctr P.R. I KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 CENTRAL REGION Clay - Dewitt 812053 345 323.1 1998 323.1 Butternut Tap included 0.0 Fly Rd Trp Included 0.0 1998 Duguld Tap included 0.0 sch 2001 Dewitt - Lafayette 812060 345 151.6 151.6 Lafayette - Oakdale 812061 345 720.4 720.4 Tully Center Loop 812195 19.5 19.5 Nine Mile - Clay 812052 345 1291.i 1291.4 Oswego - Lafayette 812055 345 573.6 573.6 Curtis St Tap , - 812137 16.0 1998 16.0 Budwleser/Lysander Tap 812229 23.2 23.2 Oswego - Volney 812056 345 438.2 438.2 So Oswego Tap 0.0 Onondaga Water Auth Tap 0.0 Volney - Marcy 812058 345 437.3 * ,, t 437.3 Black R- Lighthouse Hill 812121 115 155.1 sch In 04.05 155.1 Clay- GE 812170 115 35.4 1998 38.2 Clay - Teall t 1I 812169 115 142.9 98, 99, 00 142.9 Hopkins Rd Tap Included 0.0 Euclid & OCWA Taps Included 0.0 Crouse Hinds Tap Included 0.0 Clay - Teall I10 812172 115 149.2 80% 98 - 99 149.2 Dewitt - riden 812214 115 18.5 18.5 Rock Cut Tap 812196 42.6 42.8 Elbridge - Longbranch 812302 115 59.9 spots 59.9 Elbrldge - Geres Lock 812210 115 77.0 1998 77.0 Crucible Steel Tap Included 0.0 Geres Lock - Tilden 812152 115 66.1 1997 66.1

-* I ; I ROW Cycle 5 2001 to 08 Page 2t 12/1912001

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP CIr P.R. # KV Acres Tress 2001 2002 2003 2004 2005 2006 2007 2008 Lighthouse Hill - Clay 812217 115 352.8 sch2001 352.6 Lighthouse hill - Oswego 812118 115 374.2 85% 00 374.2 Lee Schoeller Tap Included 0.0 sch 01 Fitzpatrick Tap included 0.0 sch 01 Scriba Tap included 0.0 sch 01 Nine Ml I - Fitzpat 812247 0.0 sch 01 Scuba-Nine Mi 2 15 812248 115 0.0 schO1 Scuiba-Nine Mi 2 56 812249 115 0.0 schO1 Alcan Tap Included 0.0 . sch 01 Harnmermill Tap included 0.0 sch 01 Wine Croek Tap Included 0.0 sch 01 Varrick Tap included 0.0 sch 01 Mortimer - Elbridge 812203 115 377.7 needs 377.7 Oneida - Cortland 812224 115 194.9 good 194.9 Oswego - Clay 812141 115 140.6 needs 140.B 8

Whilaker Tap included 0.0 Nestle Tap 812142 19.8 Sealright Tap 812143 11.4 Miller & Owens IllinoisTap 812228 29.3 29.3 Owens Illinois Tap 812232 0.0 Oswego - Geres Lock 812149 115 96.3 needs check 01 96.3 Peat St - Dewitt 812188 115 48.0 1997, 99 48.0 Headson Tap Included 0.0 Bridge St Tap included 0.0 Sleight Rd - Auburn 812209 115 158.9 needs 158.9 SUNY - Cortland 812193 115 30.7 30.7 Buckbee Meaws Tap 812231 0.0 Teall - Dewitt #6 812144 115 36.2 1998 36.2 Carrier Tap included 0.0 Teall - Dewitt t4 812189 115 25.5 sch 2001 25.5 NPG & Carrier Taps 812174 1.6 50% 1.6 Teall - Oneida 812204 115 230.5 needs sch 01 230.5 BrIdgeport Tap 812166 15.8 1998 15.8 Lakeport Tap 812404 34.5 16.9 1998 16.9 Page 22 12119/2001 ROW Cycle 5 2001 to 08 I

Transmission Right-of-way Management Program - Master Brush Danger RIGHT.OF.WAY IPP Ctr P.R. S KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Borden Tap. 812403 34.5 0.5 0.5 USAF Tap 812405 34.5 2.8 1997 2.8 Woodard - Longbranch 812218 115 42.7 42.7 Cold Springs Top Included 0.0 Belmont Tap, Included 0.0 Ash - Teall t28 Jewett-Skaneatelas Falls 812527 34.5 8 13.7,. 2000 13.7 Stauffer Chemical Tap Included 0.0 0.0 Skaneatelas Falls - NYSEG Included 0.0 2000 0.0 General Crush Stone 812528 7.2 sch 2001 7.2 Skaneatelas Village Tap B12529 3.1. trim sites 3.1 Niles Tap 812528 23.1 2000 23.1 Bennett's Br - Lighthouse H 812542 34.5 7 Orion Brighton - Tildens 812473 34.5 5 29.1 1998 29.1 Drumlins Tap Included. 0.0 1998 SU Research Tap Included 0.0 1998 General Crush Stone Tap Included 0.0 1998 Bristol Hill - Phoenix 812449 34.5 7 77.7 1998 77.7 Phoenix Tap Included 0.0 Atlantic Refining Tap Included, 0.0 Burnet - Headson 812430 34.5 5 1.6 1997 1.6 Winkleman Tap included 0.0 Killian Bearing Tap Included 0.0 Syracuse Rendering Tap Included 0.0 Syracuse Industries Tap Included 0.0 Burton St- Rathburn 812601 34.5 7 13.3 2000 13.3 Cazenovla - Labrador Tap 812416 34.5 7 81.1 2000 81.1 Balina Tap Included 0.0 Truxton Sta Tap Included 0.0 Johnson Bros Lumber Tap Included 0.0 Chittenango - Whilman 812517 34.5 7 41.3 2000 41.3 Perryville Tap Included 0.0 Rathburn Tap Included 0.0 Warren Bros Ouarry Tap Included 0.0 Cortland

Munson 812506 34.5 5 37.4 1998 - 98 37.4 Tuscora Plastics Tap Included 0.0 Smith Corona Tap Included " 0.0 ROW Cycle 5 2001 to 08 Page 23 12/1912001

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. J KV Acres Trees 2001 2002 2003 2004 2006 2006 2007 2008 Pall Trinity Tap included 0.0 Guches Lumber Tap included 0.0 Cortland Wood Products Tap included 0.0 Monarch Tool Tap Included 0.0 Cortland State Tap included 0.0 Curtis St - Bristol Hill 812412 34.5 6 65.4 1997 - 98 65.4 Fairdale Tap included 0.0 Girdseye Tap included 0.0 Eureka Tap included 5 0.0 3.1 3.1 Fulton Hydro Tap Included 5 0.0 trim trim Eureka - Fay 812524 34.5 5 5.1 1998 5.1 Taps to Oswego Fails Included Curtis - Bristol Hill (Fay Sti 812496 34.5 6 31.2 1998 31.2 Millar Waste Treat Tap included West Third St Tap Included Harris Rd - Tildens 812472 34.5 5 52.3 2000 52.3 Glenwood Tap included 0.0 2000 Saunders Tap included 0.0 Headson - Minoa 812443 34.5 5 30.9 1998

99 30.9 30.9 Ratnour Bridge Tap included 0.0 Fayetteville Tap included 0.0 Meadowbrk/Limestone Treat included 0.0 Accurate Die Tap included 0.0 Headson - Tildens 812452 34.5 5 39.2 2000 39.2 Allied Crushed Stone included 0.0 Booher Lumber Tap included 0.0 Southwood Tap included 0.0 Springfield Tap 812453 2.7 2.7 Homer - Cortland #20 812457 34.5 5 26.6 1996 - 98 26.6 Lorings Asphalt Tap Included 0.0 Cortland Asphalt Tap Included 0.0 Polkvile Stone Tap included 0.0 McGraw Tap included 0.0 Homer - Cortland J23 812521 34.5 5 31.9 1996 -98 31.9 Electric Test Lab Tap included 0.0 Cortland Une Tap included 0.0 Cortland Waste Tieat Tap included 0.0 Miller St Tap included 0.0 Rubbermaid Tap Included 0.0 ROW Cycle 6 2001 to 08 Page 24 12/19/2001

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. I KV Acres Tries 2001 2002 2003 2004 2005 2008 2007 2008 Brewer Titchner Tap Included 0.0 '

Fisher Ave Tap included 0.0 r Jamesville - Tully 8124iB 34.5 7 91.4 2000 91.4 Pompey Tap included 0.0 Fabius Tap Included 0.0 Ughthouse Hill - Camden 812531 34.5 7 55.2 1998 ., 55.2 Lighthouse - Mallory 812540 34.5 7 204.0 1998 - 99 204.0 Sandy Creek Tap included 0.0 Woodville Tap included 0.0 Mallory - Cicero 812402 34.5 8 35.2 " 1997 - 98 35.2 Pepsl Tap Included Cicero Tap Included South Bay Tap 812408 18.3 18.3 *i 18.3 Mallory - Cleveland 812407 34.5 7 120.1 1998

99 120.1 McIntosh Pallet Tap Included Rutland Plywood Tap included: , . .. .

Marcellus . Solvay 812420 34.5 5 38.8 1998 38.8 38.8 Sylvania Tap included widen .

Camillus Tap included Minoa - Chittenango 812504 34.5 8 22.9 2000 22.9 Oswego - Varrick 812500 34.5 5 0.7 1998 0.7 0.7 State Teachers Tap Included Pebble Hill - Rathburn 812602 34.5 8 51.7 1998 51.7 Fayetteville Tap included 0.0 1998 Manlius Tap included 0.0 1998 i.

Solvay - Harris Rd 812458 34.5 5 34.7 1998 34.7 34.7 Fairmount Tap . included 0.0 1998 Westvale Tap Included 0.0 1998 Hinsdale Tap included 0.0 1998 Teall 025 Loop 812431 34.5 5 8.3 1998 8.3 8.3 Teall #26 Loop 812439 34.5 5 14.8 1998 14.8 14.8 Onondaga Water Tap Included 0.0 1998 Midstate Supply tap Included 0.0 1998 Court St Tap, included 0.0 1998 Syracuse China Tap Included 0.0 1998

. I:

Page 25 1211912001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT OF-WAY IPP Ctf P.R. KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Ley Treatment Tap included 0.0 199B Teall - Burnett 812429 34.5 5 5.1 1996 5.1 5.1 Eagle Metal Tap 0.0 Teall - Headson 812408 34.5 5 18.6 1998 18.6 Auto Lite Tap included 0.0 1998 Messina Springs Tap included 0.0 1998 US Holtman Tap included 0.0 1998 Fulton Iron Tap included 0.0 1998 E Syracuse Tap included 0.0 1996 Roth Steel Tap included 0.0 1996 Oberdorler Tap included 0.0 199B Teall - Industrial Loop 812401 34.5 5 7.0 1996 7.0 GE Test Site C included 0.0 1996 GE 18 Included 0.0 1996 GE 15 included 0.0 1996 GE 9 included 0.0 1996 GE 14 included 0.0 1998 GE 02 included 0.0 1998 Midler Tap included 0.0 1996 Tildens -Tully 812422 34.5 7 95.8 1995 - 2000 95.8 Sentinel Hits Tap included 0.0 1995 - 2000 Lord's Hill Tap included 0.0 1995 - 2000 Booher Lumber Tap retired - 1995 2000 ATT Tap included 0.0 1995 - 2000 Vanrick Bristol Hill 812493 34.5 7 55.6 75% 1997 55.6 Armstrong Tap included 0.0 Oswego iRecovery Tap included 0.0 walkdown + 25%

Seneca Hill Tap included 0.0 sch 2001

Minutto Hydro Tap ORION 0.0 Varrick - High Falls 812495 34.5 5 0.7 0.7 0.7 Woodard - Ash 812441 34.5 5 19.6 1998, 99 19.6 19.6 Liverpool Tap included 0.0 Galeville Tap included 0.0 Metro Treatment Tap included 0.0 Marley's Tap included 0.0 Syracuse Tank Tap included 0.0 Borden Tap included 0.0 Tie to Solvay URD included 0.0 Woodard - Crouse Hinds 812475 34.5 7 5.6 1999 5.B ROW Cyce 5 2001 to 08 Page 2B 1211912001 I

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 7th North Tap Included 0.0 Ups Rollway Top, Included 0.0 Smith & Calfery Tap Included 0.0 Packing Corp Tap Included 0.0 Gaylord Bros Tap included 0.0 Woodard - Longbranch 812455 34.5 5 51.1 1997 81.1 d1.1 Baldwinsville Tap included 0.0 Syroco Tap Included 0.0' Stiles Tap Included 0.0 Empire Freezer Tap Included 0.0 Empire Foods Tap Included 0.0 Coca-cola Tap Included 0.0 P&C Foods Tap Included 0.0 Woodard -TealI 24 812433 34.5 5 29.7 1997 29.7 29.7 Onondaga Water tap Sand Rd Tap Buckley Rd Tap 812434 Syracuse Mall tap 812548 Airport Tap 812433 Hancock tap. 812400 Wo . . . . I, Woodard - Teaff V32 5 20.8 1997 20.8 20.8 211.9 572.3 985.4 746.4 1,533.0 2,421.7 1,518.0 825.7 I. I ,.. 1. .

Page.27 12/19/2001 ROW Cycle 5- 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. N KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 NORTHERN REGION Adirondack - Porter 812002 230 799.1 799.1 X Alcoa - Browning 812111 115 1998 see Alcoa-Mcintyre Alcoa - Alcoa Cogen (new inviry 2001) 812110 115 Alcoa - Dennison 812109 115 29.8 1998 29.6 Battle Hill

Balmat 812105 115 58.0 1998 58.0 Gouverneur Talc Tap 0.0 St Joe's Lead Tap 812106 0.0 Battle Hill - No Gouverneur 812197 115 36.4 1998 36.4 Black River- Ughthouse Hill 8121121 115 168.0 1998 166.0 E Watertown Tap Included 0.0 Black River - Ft Drum 52 812243 115 84.8 1998 84.6 Indian River Tap included 0.0 Black River - Taylorville 812123 115 343.1 1995 343.1 High Falls Tap included 0.0 No Carthage Tap included 0.0 Ft Drum 11 Tap included 0.0 Ft Drum Cogen included 0.0 Champion Paper Tap included 0.0 Climax Paper Cogen Included 0.0 115 62.6 1995 62.6 Browns Falls - Newton Falls 812178 812125 115 314.6 1995 314.6 Browns Falls - Taylorville 115 105.9 1998 105.9 Colleen - Black River 812108 Glen Park Hydro Tap included 0.0 Air Brake Tap included 0.0 812235 115 92.5 1998 92.5 Coffeen - E Watertown 85.2 Colleen - W Adams 812252 115 85.2 1998 115 335.8 1998 335.8 Colton - Browns Falls 812104 schedule Colton - Carry Falls ORION 812158 115 235.5 1998 12119/2001 Page 29 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Bnish Danger RIGHT-OF-WAY IPP Ctr P.R. # KV Acres Trees 2001 2002 2003 2004 200S 2006 2007 2008 Blake Tap ORION Included 0.0 Cotton - Nicholville 812158 115 204.8 1998 204.8 Allen Falls Tap ORION 27.2 Dennison - Cotton 812241 115 235.4 1998 235.4 Sandstone Hannawe included 0.0 Raquette R Paper Tap Included 0.0 Unionville Hydro Tap included 0.0 Norfolk Tap Includred 0.0 Lake Colby - Lake Placid 812237- 115 83.9 1999 83.9 Ray Brook Tap Included 0.0 Malone-: Lake Colby 812191 115 559.1 1998 559.1 Alcoa - McIntyre 812236 115 317.4 1998 317.4 (Alcos-Browning + Browning-McIntyrel McIntyre - Colton 812112 115 339.1 1998 339.1 McAdoo Tap included 0.0 Sandstone Tap Included 0.0 Little River tap Included 0.0 Kraft Tap Included 0.0 ,

Ogdensburg Tap Included 0.0 Algonquin Tap Included 0.0.

General Crush Stone included 0.0 Pyrites

Battle Hill 812138 214.6 Dekalb Tap Included 0.0 Parishville - Nicholville 812100 115 see 812158 1998

7 Raymondville - Norfolk 812129 115 21.8 1998 21.8 812127 115 71.8 1995 71.6 Soft Maple - Moshier 812130 115 197.3 1993 197.3 Taylorville - Boonville Bremen Tap included 0.0 Lyons Falls Paper Tap 812131 10.5 schd 10.5 Burrows Paper Tap 812132 50.7 50.7 Moose Rive Tap included 0.0 812128 115 563.4 1995,2000 56.4 Taylorville

Soft Maple Elmer Tap Included 0.0 Effley Tap Included 0.0 223.3 Thousand Is - Coffeaen 812151 115 223.3 1998 12119/2001 Page 30 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Bnush D nger RIGHT-OF-WAY IPP Cit P.R. I KV Acns Trees 2001 2002 2003 2004 2005 2006 2007 2008 Bloomingdale Lk Colby 812335 46 30.8 30.8 Franklin Falls - Bloomingdale 812337 48 61.7 1996,98 61.7 Gabiels - Bloomingdale 812331 46 32.5 1996 32.5 Gabriels - Paul Smith's 812339' 46 27.0 1996 27.0 High Falls - Union Falls 812327 46 97.8 1998 97.8 Lk Cleat - Lk Colby 812334 46 43.6 1996 43.6 Lk Cleat - Tupper Lk 812332 46 106.9 1995 - 96 106.9 Loon Lk - Gabriels 812338 46 79.8 1996, 98 79.8 Paul Smnith's - Lk Clear 812340 46 58.4 58.4 Tupper Lk - Piercefield 812333 46 51.8 1999 51.8 Union Falls - Ausable 812328 46 75.0 1998 75.0 Union Falls - Franklin Falls 812329 46 81.3 1998 81.3 Union Falls - Loon Lk 812330 46 57.3 1998 57.3 Bombay - Ft Covington 812488 34.5 7 16.2 1998 16.2 Brasher - Bombay 812419 34.5 7 85.1 1998 85.1 St Regis Tap included 0.0 812481 34.5 54.9 1995 54.9 Browns Falls - Colony Colony - So Edwards 812483 0.0 812477 34.5 8 49.6 1995 49.6 Browns Falls - Newton Falls Star Lk Tap included 0.0 812482 34.5 7 29.1 1998 29.1 Colony - Mine Rd Ftanklin St - Malone 812489 34.5 7 6.2 1998 6.2 812487 34.5 7 39.4 1998 39.4 Ft Covington - Spencets Crns Westville Tap Included 0.0 812492 34.5 7 49.9 1998, 99 49.9 Malone - Chasm Falls Page 31 12119/2001 ROW Cyle 5 2001 to 08 B

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF.WAY IPP Ctr P.R.1 KV Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 Nicholville - Brasher 812418 34.5 7 54.0 1998 .I 54.0 No Lawrence Tap Included 0.0 Sealtest Tap included 0.0 Nicholviffe - Franklin St 812484 34.5 7 123.8 1998 123.8 Moira Tap ; 0.0 Tie to Spencers Crn5 812488 0.0 Spencers Crns - Malone 812490 34.5 7 37.1 1998 37.1 Franklin St Tap 812491 0.0 Battle Hill - Balmat 812783 23 7 20.1 1998 20.1 Arnold Pit Mine Tap 0.0, St Joe's Sylvia Lk Tap 812784 0.0 Battle 4111- Richvile 812706 23 8 23.7- 1998 23.7 Black River - Kamargo 812731 23 7 5.7 1998 5.7 Leray Tap Included 0.0 r.I ;;),

Brownville - Frontenac 812472 23 7 15.8 1998 15.8 State St - ATC 812720.: 7.8 1998 7.8 Carthage

Copenhagen 812792- 23 7 17.8.. 1998 17.8 Deer R Hydro Tap Included: 0.08 Carthage Mills Tap Included 0.0 Carthage - Taylorville 812774 23 8 33.8 1998 33.8 High Falls Tap Included 0.0 Coffeen - Brownville 812760 23 7 15.0. 1998 15.0 Brownville Mills Tap 812777 0.0 Coffeen- Portage 812727' 23 7 37.9 1998 37.9 Dry Hill Tap 812728 0.0 Dereriet - Carthage 812771 23 7 58.2 1998 58.2 Herrings Tap Included 0.0 Erneryville - Loomis 812788 23 7 7.3 1998 7.3 Emeryville - Mine Rd 812752 23 7 33.8. 1998 33.6 St Joe's Tap . included 0.0 Rushmore Hydro Tap Included 0.0 Glenfield - Port Leyden 812755 23 7 38.2 needs 38.2 Page 32 1 21t192001 ROW Cycle 6 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger KV Acies Trees 2001 2002 2003 2004 2005 2006 2007 2008 RIGHT-OF-WAY IPP Ctr P.R. #

0.4 0.4 Collinsville Tap 812757 1.2 1.2 Port Leyden Hydro 812756 Rock Is Hydro included 0.0 Empire Hydro included 0.0 included 3.7 3.7 Bailey Hydro Tap Hailsboro - Balmat 812790 23 7 29.8 1998 29.6 Fowler Tap 812798 0.0 Gouverneur Talc Tap included 0.0 Indian River - Evans Mills 812732 23 7 see 812788 1998 Morrison-Knudsen Tap included 0.0 Lisbon - Heuvelton 812789 23 7 19.7 1998 19.7 812751 23 7 8.9 needs 8.9 Lowville

- Glenfield I

812712 23 7 61.7 1998 61.7 McIntyre - Hammond 0.0 Morristown Sub Included 0.0 0.0 0.0 Brier Hill Tap included 10.5 Lee Rd Loop 812713 11.5 27.8 1998 27.8 McIntyre - Heuvelton 812714 23 7 Foremost Dairy Tap included 0.0 42.8 1998 42.8 McIntyre - Usbon 812715 23 7 0.4 0.4 David St Tap 812718 23 8 19.0 1998 19.0 Mill St - Black River 812733 Stone Products Tap Included 0.0 Watertown Muni Tap Included 0.0 Diamond Hydro Tap included 0.0 Knowlton Bros Paper Tap included 0.0 Beebe. Is Hydro Tap included 0.0 Sewalls Hydro Tap included 0.0 812785 23 8 21.5 1998 21.5 Norfolk - Norwood included 0.0 0.0 Barrett Quarry Tap 812754 3.7 3.7 E Norfolk Tap 18.7 1998 16.7 Philadelphia - Antworp 812700 23 7 1998 28.0 Philadelphia - Indian River 812788 23 7 28.0 2.9 Port Leyden - Boonville 812739 23 7 2.9 needs 5.6 812740 5.6 Denley Hydro Tap 12/1912001 Page 33 ROW Cycle 5 2001 to 08 a

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Sandstone - Putnam Hawley 812781 5.7 1998 5.7 State St - Little River 812721 23 7 16.3' 1998 16.3 Agway Tap Included 0.0 Taylorville - Belfort 812759 23 8 0.5 1995 0.5 Taylorville - Brewery Hilt 812787 23 7 9.5 9.5 J.P. Lewis Tap? 812768 0.0 Theresa - Philadelphia 812701 23 7 42., 1998 42.2 Theresa Muni Tpa Included 0.0 Philadelphia Muni Tap included 0.0 Philadelphia Hydro Tap

included 0.0 Indian Falls Hydro Tap Included 0.0 Sandy Hollow Hydro Tap included 0.0 1.171.0 697.7 859.1 1,354.0 1,010.0 846.7 988.6 0.0 Circults' removed following the 1998 Ica Storm Lighthouse Hill - Mallory Woodville Tap 812515 34.5 Battle Hill - Gouverneur 125 8i2703 23 Battle Hill - Gouvemaur 127 812710 23 Brownville - Chaumont 812741. 23 Canton - Sandstone 812708 23 Carthage - Copenhagen (Champion Tap) 812794 23 Chaumonut - Cape Vincent 812744 23 Pt Penninsula Tap Included Cofleen - Black River 812795 23 Cofleen - Mill St 812705 23 Portage Tap . included' Deferiet - Black River 812769 23 Frontenac - Sacketts 812743 23 Sacketts - Talcotts 812787 23 Hailsboro - Balmat (Natural Dam Tepi 812791 23 State St' Sandstone 812723 23' Potsdam - Sandstone 812780 23

-A. .

Page 34 1211912001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger RIGHT-OF-WAY IPP Ctr P.R. J KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 GENESEE REGION Alabama - Telegraph 5 115 712103 115 28.8 28.8 Batavia - Golah J117. 119 712255 115 239.9 239.9 Lapp Tsp kirkided 0.0 E Batavia Tap inckied 0.0 Oatka Tap kwuded 0.0 S.E. Batavia Station ckidad 0.0 Lockport -Batavia J107 712169 115 292.9 292.9 No Akron Tap kckjdad 0.0 Lockport - Batavia J 108 712170 115 64.1 54.1 Lockport - Batavia

112 (Lockport - Oakfield) 712338 115 24.8 24.8 (Oakfield - Batavia) 712239 115 29.4 29.4 Lockport - Mortimer J 111 712178 115 772.4 S 1999 772.4 Sour Spr - Am Break Tap wcided 0.0 Brockport Tap 712112 27.3 27.3 Hamlin Taps 712275 64.9 64.9 Mortimer - Elbridge #I, 2 712183 115 365.3 365.3 Mortimer - Golah #109 712312 69 01.3 61.3 Mortimer - Golah 511 O 712258 115 47.4 98,sch 2001 47.4 Mortimer - Sleight Rd J13, 23 712263 115 119.7 119.7 Mortimer - Ouaker 523 hchded 0.0 Golah - No. Lakeville J116 712232 115 48.7 48.7 E Golah Tap 30.2 30.2 General Foods Tap girkided 0.0 Albion - Brockpot *308 712352 34.5 7 55.7 55.7 Butts Rd Tap 0.0 Attica - No Leroy 5208 712359 34.5 7 70.8 J0.8 Attica - Wethersfield #209 712360 34.5 7 30.7 30.7 Batavla - Attica #200 712382 34.5 7 57.4 57.4 Batavia - No Leroy J223 712365 34.5 7 - 51.4 51.4 ROW Cyce 5 2001 to 08 Page 37 1211912001 I

Transmission Right-of-way Management Program - Master Brush Danger RIGIIT.OF-WAY IPP Ctr P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Brockport - GE *310 712368 34.5 6 17.2 17.2 Central Material Tap hckided 0.0 Caledonla - Golsh #213 712532 34.5 7 46.6 46.6 York Tap knckided 8.7 8.7 Carborundum - No Akron #204 712374 34.5 6 10.0 10.0 Carborundum - No Akron #205 712375 34.5 6 16.4 16.4 Gasport - Telegraph J312 712534 34.5 7 27.0 27.0 Rovalton Tap krckided 0.0 Glenwood - Medina #369 ORION 712368 34.5 7 0.5 Orion Golah - No Lakeville J218 712411 34.5 7 71.6 1998 99 71.6 Lima Tap hickided 0.0 Golah - No Lakeville #217 712412 34.5 7 35.6 1999 35.8 Golah - So Perry J853 712305 69 7 78.3 78.3 Medina - Albion #305 712436 34.5 7 39.3 sch 2001 39.3 No Akron - Attica #225 712442 34.5 7 78.0 78.0 I - . . .

78.0 County Line Stone Tap hnckbded 0.0 No Akron - Oakfield 1227 712443; 34.5 7 28.6 1998 28.6 28.6 Lancaster Tap 0.0 No Lakevilie

.224. Richmond 228 712451 34.5 7 26.6 26.6 No Lakeville - Richmond Tap #228 bcxjded 0.0 No Lakeville - Ridge #218 712452 34.5 7 58.5 58.5 No Leroy - Caledonia #203 712453 34.5 7 40.4 sch 2001 40.4 Dolomite Tap 0.0 Oakfield - Batavia #219 712458 34.5 6 27.2 27.2 Oakfield - Caledonia 1201 712459 34.5 7 104.7 1998. 99 104.7 Churchville Tap kicljded 0.0 Bergen Tap hnuded 0.0 Phillips - Medina #301 712470 34.5 6 74.0 1998 74.0 Waterport Tap Lhckjdud 0.0 ROW Cycle 5 2001 to 08 Page 38 1211912001

Transmission Right-of-way Management Program - Master Brush Danger FIGHT.OF-WAY IPP Cir P.R. I KV Acres Trees 2001 2002 2003 2004 2006 2000 2007 2008 Southland Tap nckdod 0.0 Fhillips - Telegraph 1304 712471 34.5 8 43.1 43.1 So. Newlane Tap 0.0 Retsof - So. Perry 712999 34.5 (included in Golah - So Perry inventory in 99)

Telegraph Medina 1302, 303 712500 34.5 6 41.4 41.4 41.4 Telegraph - Medina 1303 0.0 Waterport - Albion 1308 712081 34.5 d 7.9 7.9 Waterport - Brockport 1307 712507 34.5 7 91.1 91.1 Glass Tap rckjded 0.0 Waterport Hydro-Waterpt 1312 ORION 712862 34.5 7 0.6 Orion 250.0 250.7 239.9 255.7 690.7 1,360.2 437.5 104.6 Pago 39 12119/2001 ROW Cyle 5 2001 to 08

Transmission Right-of-way Management Program - Master Broth Danger IPP Ctr P.R. # KV . Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 RIGHT-OF-WAY FRONTIER REGION Beek Packard #78 712001 230 41.3 41.3 TAM Taps 712223 115 35.9 35.9 iluntley - Gardenville #79, 80 712005 230 547.8 1999 547.8 Gardenville - Dunkirk #73.74 712004 230 252.4 252.4 Niagara.- Packard #81. 82 712006 230 65.8 65.8 Packard - Huntley #77, 78 712008 230 214.4 214.4 Adams. Packard #183,184 712100 115 3.2 3.2 Alrco Speer Tap kickjded 0.0 -

Olin Corp Tap bk~cjadd 0.0 Adorns- Packard 18B7,18 712101 115 5.0 5.0 712248' 115 72.3 1999 72.3 Ellicott Jct -Getzville #36 115 144.6 1999 144.6 Gardenville - Dunkirk #14 1. 142 712139 Gardenville - Homer H1-111151, 152 712140 115 273.0 1999, 00 273.0 712271 115 48.6 48.8 Gardenville -Republic #14 5 l0.neral Mills - RidgeGI1I) inclujded 34.5 0.0 IONo .Ridge 131 bvikjded 34.5 0.0 712141 115 20.0' 20.0 Gardenville- Seneca #81, 82 712'265 115 55.8 55.6 Industrial Taps #46,47 Dunlop Tap kinclded. 0.0 -

Dupont Tap k~cludd.d 0.0 Kenmore Tap kicluded 0.0 American Brass Tap (NUG) cheek 0.0 Chevy Tap - idlljbde 0.0 115 52.5 Kensington - Gardenville #44, 45 712165 52.5 160.2 Jct. Park Club Ln - Hinman Rd, 36-39 712333 115 160.2 (old Lockport Taps) 40.6 Ludwig - Depew #54 7 12229 115 40.6 Calspan Tap - hIckided 0.0 I Ii included .0.0 Dresser Tap 12~11912001 Page 42 ROW Cycle 5 2001 to 08Pae4

Transmission Right-of-way Management Program - Master Brush Danger I'3GHT.OF-WAY IPP Ctr P.R.I KV Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 Cooper Tap kwc.dod 0.0 Mountain - Lockport &103 712188 115 110.7 1999

110.7 Swann Rd Tap ickxled 115

0.0 Beck - Harper J106 712336 69 11.7 11.7 Mountain - Niagara 121 712189 115 17.0 17.0 Niagara - Lockport 101 712143 115 158.f 1999 158.0 Gibson Tap 712251 115 17.9 17.9 Packard - luntey 129 712201 115 115.5 115.5 Tonawanda Tap inc~ed 0.0 Berhgoltz Taps kickded 0.0 Packard - Union Carbide J182 712205 115 7.5 7.5 NITEC Tap, rhkaded 0.0 Union Carbide Tap lcrided 0.0 Hooker Chem Tap khcWded 0.0 Terminals Sta D- Taps 891 712321 69 17.3 17.3 Station 867 - Walden J701 712355 23 5 29.8 29.6 Sierra Tech Tap kckjdod 0.0 Cambria - Lockport 1411 712811 12 7 7.8 7.8 So Cambria Tap removed 0.0 Lewiston Hts - Mountain #405 712431 34.5 5 1.7 1.7 1.7 Mountain - Sanborne 1404 712438 34.5 6 13.7 1998 13.7 Graphite Specialties Tap kickided 34.5 0.0 Niagara Stone Tap kichdd 34.5 0.0 Mountain - Youngstown 1401 71251B 34.5 5 24.1 1999 24.1 24.1 Phillips - Telegraph 1304 712471 34.5 Genesee So Newlane Tap Common 34.5 7 Genesee 9.8 Ransomville - Phillips 1402 712475 34.5 7 35.3 35.3 Ridge - Shaleton #810 712476 34.5 8 3.7 3.7 Buffalo Stone Tap kiwced 0.0 Sta 124 - Youngman 1605. 608 712494 34.5 8 11.0 11.0 Page 43 12119/2001 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Brush Danger P.R. # KV Acres Trees 2001 2002 2003 2004 2005 2008 2007 2008 RIGHT-OF-WAY IPP Ctr Walden - Ledyard 2702 712552 34.5 7 80' 8.0 Youngstown - Sanborne 1403 712517 34.5 7 32.8 1999 32.8 712710 23 6 20.0 3.6 3.6 Huntley - Military #22H Huntley - Woodard 028" 712770 23 e 12.5 12.5 Kenmore - SUNY Buffalo 1630, 031 712790 23 8 19.5 19.5 712741.. 23 6 12.3 12.3 12.3 Tonawanda Unes 1501 6.1 5.1 6.1 Station 79 Tips kickided 23 6 icluded 23 e 2.0 2.0 2.0 Station 77 Taps 207.0 399.4 050.7 242.0 247.7 563.6 150.2 302.1 ROW~s that have been removed

.. : . , lI - , * -,

Sanbome - So Cambria 1408 34.5 12119/2001 now cycle 5 2001 to 08 Page 44

Transmission Right-of-way Management Program - Master Btush Danger P.R. # KV Acres Trues 2001 2002 2003 2004 2006 2006 2007 2008 RIGHT.OF-WAY IPP Ctr SOUTHWEST REGION Homet City - Stolle Rd #37 712060 345 645.5 645.5 Valley - Ischua #158 712279 115 113.3 113.3 Dunkirk - So. Ripley 5 68 712003 230 538.9 538.9 '

Gardenville - Dunkirk #73, 74 712004 230 724.0 724.0 Dunkirk - Falconer #1860 712122 115 348.0 98. *ch 2001 348.0 Columbia Gas Tap nkkdcd 0.0 Curmnins Engine Tap icxkded 0.0 Baker St Tap inckided 0.0 712121 115 329.8 sch 2001 329.8 Dunkirk - Falconet #5 1. 162 Roberts Rd Tap kxchwd 0.0 712132 115 453.9 99, sch 2001 170.0 170.0 229.3 Falconer - Homer Hill J 153. 154 Harb Carb Tap ,emoved 0.0 reserv St reserv Isl Salamanca Taps (21 kxhAced 0.0 115 48.6 24.3 Falconer - Warren # 171 712133 115 293.9 99, sch 2001 293.9 Gardenville - Dunkirk #141, 142 712139 Ridge-Shaleton Jo1O common 0.0 2000 ECWA Tap imckded 34.5 0.0 115 100.2 1999, 00, 01 100.2 Gardenville - Homer Mill 151, 152 712140 712155 115 60.4 60.4 Harttield - Moons # 159 460.4 Homer Hill - Bennett 5 157 712264 115 460.4 '1 1999 48.8 Dugan Rd Tap 5157 712120 48.6 18.5 Homer Hill - Olean #155- 712158 115 16.5 50.9 Dugan Rd Tap #155 712119 50.9 712231 115 8.0 6.0 Willowbrook - Brigham #164 712358 34.5 7 57.4 sch 2001 57.4 Ashville - So. Dow #884 60.2 Bagdad - Dake Hill #815 712381 34.5 7 60.2 2000 43.8 Cold Spr - W Selamanca #804 712384 34.5 7 43.8 sch 2001 ocklAded 0.0 So Randolph Tap 12/19/2001 Page 47 ROW Cyce 5 2001 to 08

Transmission Right-of-way Management Program - Master Bnrsh Danger lIGHT-OF-WAY IPP Ctr P.A. I KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Dake Hill - Machias #803 712388 34.5 7 119.9 sch 2001 119.9 Nuclear Fuels Tap imked 0.0 Dake Hill - W Salamanca 181I 712389 34.5 7 74.1 2000 74.1 Delevan - Machias #801 712390 34.5 7 22.4 sch 2001 22.4 Farmersville Tap cmkied 34.5 0.0 Dunkirk -W Portland f851 712395 34.5 7 35.4 sch 2001 35.4 Dunkirk - Harttield 0852 712394 34.5 7 63.3 a 1999 83.3 Sinclairville Top hkckided 34.5 0.0 So Dow - Poland 1865., 712400 34.5 7 9.9 9.9 Levant Tap kckjded 0.0 Jamestown Sewage Tap deewrwized Hartileld - Ashville #854 712417 34.5 5 33.0 33.0 33.0 Hanfield - Falconer 1859 712418 34.5 5 100.0 1998 100.0 100.0 Hart feld - Sherman J855 712419 34.5 7 28.7 26.7 Machias - Maplehurst t802 712435 34.5 7 80.1 1999 80.1 Buffalo Slag Tap 712372

34.5 0.0 Nile - So Wellsville 1812 712441 34.5 6 61.4 s 1999 81.4 Petrolla Tap 712469 0.0 No Angola - Bagdad 0857 712444 34.5 7 65.3 1998, 99 65.3 0.0 0.0 Prison Tap hIckided PPenysburg tap., h~cluded 11.9 11.9 712445 34.5 7 72.4 1998, 99 72.4 No Angola - Bagdad 1862 Prison Tap khckWed 0.0 712446 34.5 7 63.1 1999 63.1 No Angola - No Ashford l8O1 No Eden Tap imckhd 0.0 No Ashford - Nuclear Fuels 712447 34.5 7 15.0 sch 2001 15.0 34.5 7 35.0 1999 35.0 Olean - Ceres #809 712481 No. Olean Tap 0.0 Cutco Cuttlery Tap hkviuded 0.0 712464 34.5 7 95.8 1999, 00.01 95.8 Olean - Nile #811 Cuba Tap Inekided ' 0.0 I 12/1 9/2001 Page 48 ROW Cycle 5 2001 to 08

Transmission Right-of-way Management Program - Master Btush Danger RIGHT-OF-WAY IPP Clu P.".1 KV Acres Trees 2001 2002 2003 2004 2005 2006 2007 2008 Cuba Lk Tap ckided 0.0 Homer Hill - W Salamanca 1805 712513 34.5 7 93.4 1999.00 93.4 Sherman . Ashville 1863 712483 34.5 7 67.5 a 1999 67.5 Findley Lk Tap mckided 0.0 French Ck Tap 0.0 So Wellsvile - Andover 0541 712489 34.6 6 45.3 2000 45.3 Preheater Tap 0.0 Whhtesville Tap kwkded 0.0 W Portland - Hartliald 8868 712509 34.5 7 35.1 sch 2001 35.1 W Portland - Sherman 0867 712510 34.6 7 75.8 1999 75.8 538.9 1.409.9 782.4 121.8 724.0 879.2 867.8 602.2 Page 49 12119/2001 ROW Cyle 5 2001 to 08

APPENDIX 7 GAS RIGHT OF WAY STATISTICS BY REGION REQUIRES EIEELURE LENGTH MAINTENANCE ACRES (Ms (Mflln CAPITAL REGION Broadway - Burdeck E7 3.1 3.1 7.5 Burdeck - Seneca E8 5.4 5.4 13.1 Rotterdam - GE Tap E8 0.5 0.5 1.2 Freeman's Bridge Tap E 8A 0.2 0.2 0.5 Seneca - Saratoga E 13 10.7 10.7 25.9 Wolf Rd. - Fuller Rd. E 14 2.7 2.7 6.5 Fuller Rd. - Western Ave. E 15 1.0 1.0 2.4 Smith Ave. - Shaker Rd. E 16 6.3 6.3 15.3 E 17 7.8 7.8 18.9 Smith Ave. - Eastmor Rd.

E 18 15.9 15.9 38.5 Putnam Rd. - Saratoga Putnam Rd. - Rt. 67 E 20 3.1 3.1 7.5 Eastmor Rd. - Troy E 20 I 3.0 3.0 7.3 Water St. Tap E21 25.0 25.0 60.6 Brookview - Hudson E 23 1.8 1.8 4.4 Wolf Rd. - Shaker Rd.

E29 4.0 4.0 9.7 Normanskill - Western Ave.

Page 1

GAS RIGHT OF WAY STATISTICS BY REGION REQUIRES ELEIM LENGTH MAINTENANCE ACRES 0(114 (MJles)

Normanskill - Port (Albany Stm) E 30 4.1 4.1 9.9 Brookview - Ft. Gage E 32 2.7 2.7 6.5 BASF Cogen E 35 1.8 1.8 4.3 Total 99.1 99.1 240.0 Page 2

GAS RIGHT OF WAY STATISTICS BY REGION REQUIRES EIRELt NO. LENGTH MAINTENANCE ACRES (Mles (Miles)

NORTHEASIREGION Marshville - Canajoharle E-1 2.1 2.1 5.1 Queen Ann - Gloversville E2 11.1 11.1 26.9 Shellstone - Queen Ann E5 11.2 . 11.2. 27.2 Gick Rd. - Glens Falls E 12 5.4 17.6 42.7 Seg 1. Saratoga - Gick Rd. 5.4 Seg 2. - Gick Rd. - Glens Falls 11.5 South Glens Falls - Kamine 0.4 Seneca St. - Gick Rd. E 13 11.8 11.8. 28.6 Putnam Rd. - Saratoga E 18 12.7.

Rt. 67 - Saratoga 12.7 30.8 Saratoga - Glens Falls E31 16.8 16.8 40.7 Corinth Cogen E 33

6.4 6.4 15.5 Total 94.8 89.7 217.5 Page 3

GAS RIGHT OF WAY STATISTICS BY

. REGION REQUIRES PIPELINE LENTIH MAINTENANCE ACRES (Miles MOHAWK VALLEY REGION Higby - Yorkville 11 8.7 8.7 21.1 Higby - Harbor Point 13 6.7 6.7 16.2 Scribners - Lamphere 15 14.9 14.9 36.1 Scribners - Barge Canal 16 10.6 10.6 25.7 near Rt. 5 Vickerman Hill - Illion Cogen 60 3.8 1.0 2.4 PL 15 - Sherrill 61 1.3 1.3 3.2 Total 46.0 43.2 104.7 Page 4 a

GAS RIGHT OF WAY STATISTICS BY REGION REQUIRES EIPELIE 'NQ, LENGTH MAINTENANCE ACRES (Mlles) (Miles)

CENTRAL REGION Barge Canal - Chestnut St.(Phoenix) 16 29.3 29.3 71.0 Spur into Taft Rd. 0.5 0.5 1.2 Spur Into Davis Rd.(No. Syr.) 0.4 0.4 1.0 Therm City - Fair Gmds.(Bridge St. & 21 10.9 State Fair Blvd.)

Seg 1. Therm City - Bussey Rd.(common w/ #31) 4.3, 20.8.

Seg 2. Bussey Rd. - Tauton:(common w/ #35) 5.0 24.2 Tap off PL# 50 - Longbranch 29 4.1 4.1 9.9' Therm City - Andrews Rd.(Dewitt) 31 15.5 Seg 1. Therm City - Bussey Rd' see PL #21 4.3 10.4 Seg 2. Bussey Rd. - Andrews Rd: by itself 11.2 27.2 Longbranch - Burt St. (Oswego) 32 20.3 20.3 49.2 Spur to Cold Springs (see PL #36)

Kingdom Rd: -Sandy Crk (Caster Rd.) 33 26.0 26.0 63.0 Spur into Schoeller Paper 33 A 2.7 2.7 6.5 Burt St. - Walnut St. (Oswego) 34 --11.9 ' 11.9 ' 28.8:

Therm City - Bussey Rd. 35 A 5.4 5.4 13.1 Bussey Rd. - Taunton (see PL #21) 35 5.0 5.0 Page 5

GAS RIGHT OF WAY STATISTICS BY REGION.

REQUIRES PIPELINE LENGTH MAINTENANCE ACRES (Miles) (Miles)

Taunton - Longbranch 36 9.4 9.4 22.8 Spur into Cold Springs incl PL #32 spur 0.8 0.8 1.9 Spur Into Knoll Rd. (all in streets) 0.5 Spur into Pottery Rd. 0.3 0.3 0.7 Taunton - Hiawatha (spots) 38 2.7 spots Chestnut - Sandy Crk (Scott Rd.) 39 34.0 34.0 82.4 Taft Rd. - Court St. 41 5.5 5.5 13.3 Hiawatha - GM Circle 50 4.6 4.6 11.2 Kingdom Rd. - Walnut St. 51 6.0 6.0 14.5 Velasko Rd. - Syr. Univ. 52 2.7 Walnut St. - Oswego Steam 55 3.5 3.5 8.5 Hall Rd. - Indeck (Oswego) 58 12.6 12.6 30.5 Chestnut St. - Sithe 63 24.9 24.9 76.6 PL #41 - Bristol Cogen 65 3.5 1.0 2.4 Total 243.0 233.0 591.1 Page 6

GAS RIGHT OF WAY STATISTICS BY REGION REQUIRES PIPELINE LENGTH MAINTENANCE ACRES (MlIls) (M11s4 NORTHERN REGION Sandy Crk. - Holcomb St. 33 26.8 26.8 65.0 (starts @ Kaster Rd.)

Rices Rd. - Holcomb 43 2.3 2.3 5.6 Rt. 81 - Leray Rt. 3 48 3.6 3.6 8.7 Rices Rd. - Rt. 81 49 6.2 6.2 15.0 Holcomb St. - Carthage 56 22.0 22.0 50.0 Carthage- Indian River 64 15.2 15.2 35.9 Total 97.7 97.7 232.6 Page 7

APPENDIX 8 RI I JAGARA .N1AGA.-AAMOHAWK NU MOHAWK . RIGHT OF WAY - FULL INVE NTORY P.ROM OSWEGO TO CLAY (Renumbered Site Numbers)

Property Rec#: 812141 (:Width) From: 050 to 150 Forester: KLK . Region 112: 54 /. . Owner: Mixed - Contractor: -L. -7 Line#VT 334 . Volts: 115 Length: 12 Article 7: No :.; -Sched. Year: 01 Schd " .Land . . Species Species * * - -

Slte# Irap# ~Yr ..(Reg From# To#f Wid Len Acres Use Trt Corn UNDES IRABLE DESIRABLE Chein Gals Date

'109l-g 01 54 '215.2-5 '215.25 '100 43 0.1. 8213 ST- No ELM, A.' SHDO G V B- 4 . _ _

Corn: HEDGEROW Sens:No Own:No Urgent: No

,/110 - 01 . 54 -21 5.25 . 216.50 ., 100 609 1.4 8212 -I2~ No BCH,H] .C DOG, VIB -A . v c p o Sens: No Own: No Urgeuit:No.

11015 --2 5'6.50.-

-. 100 --43--0.1-8211. *ST No HIC,BC H ~~VIB, ELD . . L. O ) y /' I J .

Corn: HEDGEROW/ST SUMAC,' . i .

Sens: No Own: No .Ugn No.*

.' 112 01 54 216.50 219.25 1 '4051

'I00 . 9.3. 6000" OF - No Sens: No Own: No" Urgent: No vi113 ADD 01 54 216.50 219.25' 100 _ 150 0.3..6220 'ST MAP..

SesNo' Own: N' Urgent: No v.I 14 ADD 01 54 -219.25 21il9.25' 10 4 .1 8'21L ST HIC DOG ". ,e 00 Q~~~

Corn: HEDGEROW Sens: No Own: No Urgent: No

',Yl115 ADD 01 54 219.25' 223.25 100 2370 '5.4 6000 OF Sens: No Own: No Urgent: No".

"1116 ADD 01 54 223.25 223.25"1060 ~'180 0.4 6220 ST ; MAP Corn:4 STR SIES - Sens:No-. Own:No " Urgent: N~o d/117' - . 01 54 223.25 223.75 1100 '440 ;. 1 8222 "LSF No BCH Corn: HILLSIDEIACCESSTO FIELDS FROM THIS RD.', SensN O i:NUrgent: No" SM C 2 0

' 118 01 54 ' , 223.75 224.25 100 261 0.6 3212 ST No BCH ' o -0 & , § 2 Uom: UUU41I X nUnw I Iii Sens: N Own: No Urgent: No

.A19 : 01 54. 224.25'.225.75 `100 - 871- 2 4000 OF ' No _ _ I-' .

Corn: GOLF COURSE I Sens: No Own: No. Uirgent: No 01 54 225.75 226.75 1U0 479 1.1 2111 zff NO AbH1 DOG -- dyAg2i" Sens: No Own: No Urgent: No Printed April 12.2001 / Page I10 RPT2010

' aml JIAGARA NIAG,. _A MOHAWK 11 U MOHAWK RIGHT OF WAY - FULL INVENTORY FROM OSWEGO TO CLAY (Renumbered Site Numbers)

Property Rec#: 812141 [Width] From: 050 to 150 Forester: KLK Region 1/2: 54/ Owner: Mixed Contractor: L7 1 Line #: T 334 Volts: 115 Length: 12 Article 7: No Sched. Year: 01 Schd Land Species Species Site#/Tap# Yr Reg From# To# Wid Len Acres Use Trt Com UNDESIRABLE DESIRABLE Chem Gals Date 133 01 54 241.75 242.50 100 435 1. 6000 OF No O.

Scns: No Own: No Urgent: No 134 01 54 242.50 243.25 100 304 0.7 5000 OTH No °tJti° Sens: No Own: No Urgent: No 135 01 54 243.25 244.00 100 435 1 8221 ST No ELM VIB, DOG /. 0 o a C Sens: No Own: No Urgent: No

/ 136 01 54 244.00 245.00 100 359 0.8 3121 ST No MAP DOG, VAB, W1L - o 'o'o cfy/jo Com: COUNTY HIGHWAY 121HOUSE CLOSE Sens: No Own: Yes Urgent: No J 137 01 54 245.00 246.00 100 435 1 8221 ST No MAP DOG, VIB, HAW, APP * ) °A /i ° Com: NEAR HOUSE/TRM PINE DTW: M2 DTFt:500 Skid:Yes Sens: No Own: No Urgent: No J 138 ADD 01 54 246.00. 248.50 100 1060 2.4 2233 ST ASH, MAP DOG, SPB _ CL?. .C~.;'Zi6 Corn: CUT ASH/MAPLE DT'S LSF SMALL STEMS

DTW:LI DTFt:500 Skid:No Sens: No Own: No Urgent: No

%W139 01 54 248.50 250.00 100 0950 2.2 9342 SF No MAP, ASH VIB, SPI & - A/,s 3( 1.r&I/l

+/-

Corn: ACCESS FROM SNOWMOBILE TRAIL S-I- ;A// Sens: No Own: No Urgent: No

140 01 54' 250.00 250.75 100 0550 1.3 8222 .W No ASH,MAP DOG, VIB, WIL 4 Q OTi~ l i 56 Sens: No Own: No Urgent: No J 141 01 54 250.75 251.50 100 0450 ^1 5212 ST No ASH VIB, DOG , 4CiO a4 *Ž 2 Com: NORTHLAND DR Sens: Yes Own: Yes Urgent: No j 142 01 54 251.50 251.75 100 150 0.3 5000 OF No )eLK I1ig Com: TRM YARD TREE DTW:MI DTFt:100 Skid:No Sens: No Own: No Urgent: No J143 01 54 251.75 253.00 100 700 1.6 5340 . No-^MAP, ASH A o 00 3 o Corn: MUST BE STUMP TREATED '. TV \ Sens:No Own: No Urgent:No 144 . .

Coin: THELMA 01 fq 4.

54 253.00 253.25 100 150 0.3 5320 TRM Yes PIN JSi971;&e 5Ae// ;

Sens: No Own: No Urgent: No Printed April 12,2001 Page 1 RPT2010

APPEDIX ASN National Aged Um oran If.'m - ,

for Hoewuevs aong

Tra~n oo59,01Imigllts-Of-Way

Our Vegetation Management Department will soon carry out routine maintenance on the electricity,transmission

right-of-way on or adjacent to your property. A variety of Integrated Vegetation Management (IVM) methods will be used, including hand cutting, mowing, and selective herbicide application, and will be implemented by our licensed and experienced contractors: X IVM is essential to provide safe and reliable delivery of electricity. It prevents tall-growing vegetation from growing :

into the overhead lines. In addition,'we manage vegetation c to allow access to the lines for routine maintenance and for restoration of electric service following major storms By implementing IVM methods, we create stable, low-growing plant communities that require minimal maintenance and '

disruption of the environment. These plant 'communities pro-vide a healthy wildlife habitat, especially for those animals requiring open fields, meadows, and shrubs.

Use of herbicides within our IVM approach is regulated by federal and state statutes and regulations. These requirements protect sensitive areas such as:

- surface water supplies - wetlands

- public and private wells -visually sensitive sites near roads and 'residences The work takes place In up to four phases:

u Crews hand cut all hardwood and conifer trees within the right-of-way, and identif and mark appropriate buffers surrounding public water supplies, private wells, streams, ponds, lakes, and residences.

r. Crews treat the stumps of c ut hardwood trees with herbicide to prevent re-sprouting.

flMSelective foliar (leaf) application of herbicides, primarily to hardwood trees, takes placein summer.

t Follow-up work at roads and yards Is caried out in autumn.

i If you have a private water supplylwell that Is within 100 feet of the right-of-way, please call the contractor designated below.

The contractor doing the work in your area is:

The contractor's representative is:

and may be contacted at:

The electric company identification'for the right-of-way is:

We at National Grid believe our'IVM approach to right-of-way vegetation manage-ment is the most environmentally friendly and customer-friendly way to accomplish this necessary task. We would be happy to answer any questions you may have as the work is carried out.

EP2272 8/00

AL-1 National Grad Important Information for Homeowners along Transmission Rights-of-Way Our Vegetation Management Department will soon carry out selective side trimming and/or "danger tree" removal along the electric transmission right-of-way on or adjacent to your property. Our goal isto ensure safe and reliable delivery of electricity. The work will be completed by licensed and experienced contract tree crews.

Side trimming procedures consist of tree crown reduction and/or selective trimming of branches from trees growing along the right-of-way corridor posing an immediate or potential threat to the lines. In such cases, trimming is performed by removing treetops and upper limbs to produce a "rolled back" effect, directing tree growth away from the line.

Danger trees are defined as trees that due to their species, location and physical condition pose a significant risk of contacting the lines. When danger tree removal occurs, a tree (or trees) growing within or beyond the width of the right-of-way are completely removed. While we aim to selectively trim rather than remove trees, removal may be necessary when a danger tree poses a direct threat.

As the work iscarried out, crews attempt to reduce visual impacts as much as possible. Cut tree branches are diced close to the ground and left to decompose. Stumps are left as low as possible. Logs are cut and piled along the right-of-way edge following danger tree removal. As a result, aesthetic quality ismaintained to the greatest extent possible.

In instances where trees off the right-of-way corridor need to be removed, our contractors will contact the property owner prior to carrying out the work.

The contractor doing the work in your area is:

IThe contractor's representative is:

iand may be contacted at:

The electric company identification for the right-of-way is:

. If this box is checked, our contractor has determined that we need to discuss side trimming and or danger tree removal on your property.

Please contact the person listed above.

APPENDIX 10

+ National Grid National Grid Transmission USA Kenneth Kirkman Senior Transmission For:ster National Grid Service Company March 19, 2003 Janet H. DeixIer Secretary NYS Department of Public Service 3 Empire State Plaza Agency Building Three Albany, NY 12223

Dear Ms. Deixler:

Attached please find the following submittals relating to our transmission right-of-way management program:

1. 2002 Transmission Right-of-way Management - Herbicide Use Report.

2. 2002 Niagara Mohawk Power Corp. - Herbicide Code Sheet.

3. 2002 Transmission Right-of-way Management - Acres and Cost by Technique.

4. 2002 Transmission Right-of-way Management - Completions, including hazard tree work, mowing and substation treatments for the year.

5. 2002 Transmission Right-of-way Management - Acres by technique for work performed in the Adirondak Park.

6. 2002 Transrmission Right-of-way Management - Surrmary of Access Road, Fence and Gate work.

7. Transmission Right-of-way 2003 Management - Schedules We are currently sending our annual transmission right-of-way vegetation management program notifications to the NYS Department of Environmental Conservation (DEC) and NYS Department of Health - County Offices. Late in 2002, we submitted schedules and maps to the DEC for compliance with our multi-year wetland permit.

Sincerely, Kenneth Kirkman Senior Transmission Forester (315) 428-5273 Attachments Cc: C. M. Allen, R. W. Cummings, Jr., M. F. Mahoney, T. E. Sullivan, D. Morrell (PSC Staff)

National Grid 'irpffmIaion USA~

New Yore 2Q02 Herbicide Use Reiport Mixture Gal I Conc2-:t. Gal /

Technicue Code Chemical Gallons Acres Acre gallon4 Acr Cut / - A Pathway 430 430.0 Stumptreat B Accord/Glypro 78 31.2 E Garlon/Stalk 31 6.2/ .31 539 1,807.4 0.30 461 0.26 High Volume F Tordon/Garlon 32,982 828.9 39.80 164.9/ 0.35 Foliar 123.7 Hydraulic G TordonlOl/ 42, 666 373.3 Low-Volume Garlon 4 266.7 Foliar H Accord/ 1,125 16.9 Arsenal 4.2 J Glypro 28, 613 321.9 Arsenal 107.3 M Accord/ 4,275 64.1 Arsenal 5.3 P Krenite/ 1.600 32.0 Arsenal 6.0 Q Accord C/ 805

9.0 Escort 16.21 oz T AccordC/ 971 10.9 Arsenal 3.1 Escort 16.1 oz 80,055 2,057.9 38.90 1220.7 0.59 Backpack K Accord/ 424 21.2 Low-Volume Arsenal 2.1 Joliar L Glypro 1212 45.5 Arsenal 6.1 R Krenite 55 2.8 Arsenal 0.3 1,691 804.1 2.10 77.9 0.10 Total Concentrate Gallons Accord 102.2 Glypro 418.5 Arsenal 134.3 Stalker 0.3 Tordon 101 538.2 Garlon 4 396.5 Pathway 430.0 Krenite 2.8 2,022.8 Escort 32.7 ounces Page 1

NMPC - HERBICIDE CODES FOR BRUSH CONTROL - YEAR 2002 Code Trade Name EPA Percent Aaive Mixtu Treatment A Pathway 62719-31 5A% Picloram Premixed, Ready-to-use Stump 20.9% 2,4-D B Accord w/Water 524-326 41.5% Glypho. 50% Accord/50% Water Stump C Accord C. or Glypro w/Water 524-343/62719-324 53.8% Glypho. 40% Accord C160% Water Stump D Pathfinder II 62719-176 13.6% Triclopyr Premnixed, Ready-to-use Basal E Garlon 4/Stalker 62719-40 61.6% Triclopyr 20% /1% in Hi-Grade Oil Basal 241-398 27.6% Imazapyr F Tordon 101/Garlon 4 62719-5 10.2% Picloram 2 qtsJi.5 qts. in 100 gals. Water Selective Foliar Hydraulic High Volume 62179-40 39.6% 2.4-D (0.5% Tordon 101/0.375% Garlon4) (SF) 61.6% Triclopyr G Tordon 101/Garlon 4 62719-5 10.2% Piclorarn 3.5 qtsJ2.5 qts. in 100 gals. Water Selective Foliar Hydraulic Low Volume 62719-40 39.6% 2.4-D (0.875% Tordon 101/0.625% Garlon 4) (SF) 61.6% Triclopyr H Accord/Arsenal 524-326 41.5% Glypho. 6 qtsJlI5 qts. in 100 gals Water Selective Foliar Hydraulic Low Volume 241-346 28.7% Imazapyr (1.5% Accord/0.375% Arsenal) (SF)

J Accord C or Glypro/Arsenal 524-343/62719-324 53.8% Glypho. 45 qtsJi.5 qts. in 100 gals Water Selective Foliar Hydraulic Low Volume 241-346 28.7% Imazapyr (1.125% AccordC10375% Arsenal) (SF)

M Accord/Arsenal 524-326 41.5% Glypho. 6 qLsJl pt in 100 gals Water Selective Foliar Hydraulic Low Volume 241-346 28.7% Imazapyr (1.5% Accordl0.125% Arsenal) (SF)

N Accord C or Glypro/Arsnal 524-343/62719-324 53.8% Glypho. 4.5 qtsJIl pt. in 100 gals Water Selective Foliar Hydraulic Low Volume 241-346 28.7% Imazapyr (l.125%AccordCtD.125%Arsenal) (SF)

P Krenite/Arsenal 352-395 41.5% Fosamine 2 galsJ1 5 qts. in 100 gals. Water Selective Foliar Hydraulic Low Volume 241-346 28.7% Inazapyr (2% Krenite/0.375% Arsenal) (SF)

S Accord/ArsenaVEscort 524-326 41.5% Glypho. 6 qtsJlIS qtsf oz. in 100 gals. Water Selective Foliar Hydraulic Low Volume 241-346 28.7% 1mazapyr (1.5% Accord/0.375%ArsenaiEscort) (SF) 352439 60.0% Metsulfuron Q Accord C*/Escort 524-343/62719-324 53.8% Glypho. 4.5 qtsJ2 oz. in 100 gals. Water Selective Foliar Hydraulic Low Volume 352439 60.0% Metsulfuron (1.125% Accord C/Escort) - (SF)

T Accord C*/Arsenal/Escort 524-343/62719-324 53.8% Glypho. 4.5 qtsJI 5 qtsl2 oz in 100 gals. Water Selective Foliar Hydraulic Low Volume 241-346 28.7% Imazapyr (1.125% Accord C/0.375%Arsenal/Escort) (SF) 352439 60.0% Metsulfuron K Accord/Arsenal 524-326 - 41.5% Glypho. 5 galsJ2 qts. in 100 gals- Water Selective Foliar Backpack Low Volume 241-346 28.7% Imazapyr (5% Accord/0.5% Arsenal) (LSF)

L Accord C or Glypro/Arsenal 524-343/62719-324 53.8% Glypho. 3.75 gals/2 qts in 100 gals Water Selective Foliar Backpack Low Volume 241-346 28.7% Imazapyr (3.75% AccordC/0.5% Arsenal) (LSF)

U Accord/ArsenallEscort 524-326 41.5% Glypho. 5 galsJl qtJ4 oz. in 100 gals. Water Selective Foliar Backpack Low volume 241-346 28.7% Imazapyr (5% Accord/0.25% Arsenal/Escort) (LSF) 352439 60.0% Metsulfuron V Accord C*/ArsenaEscort 524-343/62719-324 53.8% Glypho. 3.75 galsJl qL/4 oz. in 100 gals. Water Selective Foliar Backpack Low Volume 241-346 - 28.7% Imazapyr 3.75% Accord C/0.25% Arsenal/Escort) (LSF) 352-439 60.0% Metsulfuron R KrenitetArsenal 352-395 41.5% Fosamine 5 galsJ2 qts. in 100 gals. Water Selective Foliar Backpack Low Volume 241-346 28.7% Imazapyr (5% Krenite/0.5% Arsenal) (LSF)

W Krenite/Arsenal/Escort 352-395 41.5% Fosamine S galsJIl qtJ4 oz. in 100 gals. Water Selective Foliar Backpack Low Volume 241-346 28.7% Imazapyr (5% Krenitel0.25% ArsenalEscort) (LSF) 352439 .- 60.0% Metsulfuron X Tordon K/Garlon 4 62719-17 24.4% Picloram 2 gaL3 gals in 100 gals. Water Selective Foliar Backpack Low Volume 62719-40 61.6% Triclopyr 2% Tordon K/3% Garlon 4 (LSF)

Z Test Plots NOTE: Once Accord inventory is exhausted. Accord Concentrate and Glypro will be used. Both products have a higher concentration of active ingredient (glyphosphate). *Either Glypro or Accord Concentrate may be used in these mixes.

2002 Soil Sterilan 8 lbs. Krovar/3 ozs. Oust per 100 gals Water per acre 1.5 ozs. Telar/2 qts. Accord/3 ozs. Oust per 100 gals Water per acre 3 pts. Arsenal/4 ozs. Oust per 100 gals. Water per acre HerbcdO2.doc - 8/27/02

NIAGARA MOHAUK POWER CORPORATION DATE 03/03/03 TPANSMISSION RIGHT OF WAY PAGE 1 COST OF TREATMENT SCHEDULED YEAR 2002 SYSTEM REPORT

- TOTAL COST ACRES AC-COMP COST / ACRES OPEN FIELD 1,517.5 1,517.5 MOUING 47,629.30 299.9 299.9 158.81 LOU VOLUME 124,115.71 804.1 804.1 154.35 STEM FOLIAR 490,698.58 2,886.8 2,886.8 169.98 BASAL STUMP TREAT 382,986.31 1,563.4 1,563.4 244.97 STUMP TREAT UR 46,228.53 118.0 118.0 3i1.76 SThP TRT CH 120,547.24 126.0 126.0 956.72 TRIM 186,449.58 184.4 184.4 1,011.11 CUT NO HERB 44,322.40 202.? 202.9 218.4; CUT IND NOH 1,620.80 4.1 4.1 3,5.31 EXPERIMENTAL OTHER 1,277.3 1,277.3 SUB TOTAL UORK ACRES $ 1,444,598.47 6,189.6 6,189.6 $ 233.39 TO7hL $ 1,444,598.47 8,984.4 8,N4.4 S 160.78

======---=================== -- -- ==-=====--===--=-====-====================================------ ================-- =

2002 Transmission Floor Schedule Capital Region Line - - 'Completed Brush Acres Edic-New Scotland 919.2 912339 Johnson-Maplewood -* 24.8 912023 Rotterdam-New Scotland 55.3 912305 Ballston-Mechanicsville 81.6 912008 Greenbush- Hudson 176.3 tI 912250 Norton-Menands 11.7 912078 Rotterdam-Scotia 10.6 912243 Total 12795 Voltage cost manhours edge distance S/mile Danger Trees Capital Misc.

900112 Transmission,spot $52,180.32 1,317 912020 Spier- Rotterdam $11,837.41 260 ' 5,400 912104 Porter - Rotterdam 230 $47,726.78 804 31,612 Maplewood -

912157 Menands, - 34.5- - $7,215.16 150 1,400 Greenbush -

912222 Stephentown ; 115; $61,991.90 1,216 64,511 912295 North Troy - Hoosick 115 $14,354.32 312 2,700 912344 Renolds Rd. - Alps 345 $59,436.87 1,200 57,455

$202,562.44 3,942 163,078 $6,558

a-_

2002 Transmission Floor Schedule

-'Northeast Region Line Completed Brush Acres Inghams-St Johnsville 36.7 912027 Glens Falls-Mohican #11 20.2 912028 Amsterdam- Ephratah 154.9 912069 Cement Mountain- Schuylcrville 21.6 912097 Cobleskill- Sumnmit 21.8 912133 Cement Mountain-Stevens S Thompson 6.6 912145 Glens Falls- Mohican #12 1.3 912232 Canajoharie- Marshville 3.8 912289 Total 266.9 Northeast Danger Trees Voltage cost nnanhours edge distance Simile Misc.

912000 Transmission,Spot $1,083.98 30 912051 Mohican - Whitehall 115 $18,973.97 410 2,400 White Hall -

912072 Ticonderoga 115 $10,308.31 192 3,730 North Creek - Indian 912294 Lk. 34.5 $198,028.74 __

3,518 62,956 1

$227,311.02 4,120 69,086 $17,373

2002 Transmission Floor Schedule -

Central Division Line ' Comnpleted Brush Acres Volney-Marcy 558.5 812058 Boonville-Porter 205.1 812161 Porter-Terminal 34.9 812179 Dunlop Tap incl 812180 Tenninal-Schuyler 42.6 812126 Trenton-Middleville 75.5 812349 Trenton-Whitesboro 130.0 812358 Westmoreland-Yahnundasis #24 40.4 812368 Total 1087.2 Edge Mohawk Valley Danger Trees Voltage Cost MNHRS Distance $Imile Misc. Transmission, 812000 Spot $16,271.82 440 812001 Adirondack - Porter 230 $75,333.00 1,292 39,406 812004 Porter - Rotterdam 230 $55,782.84 1,192 80,300 812161 Boonville - Porter 115 $3,209.82 60 : 2,000 812164 Porter - Schuyler 115 $11,339.52 240 5,000 812346 Schuyler - Valley 6. $18,976.70 420 6,500

-46 812372 Valley - Inghams #24 46 $33,276.40 740 45,000 812379 Old Forge - Raquette L. $1 1,722.85 2469 3,000

$296 1.1.,

$209,641.13 4,1 90 181,206 $6,109

EL-2002 Transmission Floor Schedule Central Division Ti Completed Brush Acres Central Region Volney-Marcy 345kV 366.5 812058 Gereslock-Karnine 115kV 2.2 812153 Gereslock-Ononadaga 115kV 16.9 812151 Woodard-Longbranch#29 65.1 812465 Woodard-Teall #24 36.1

.812433 Woodard-Tcall #32 43.9 812451 Teall-Burnet 4.9 812429 South Bay Tap 15.5 812406 Buckley Road Tap 2.4 812343 Total 553.5 Central Region Danger Trees Voltage cost manhours edge distance $/rnie 812000 Misc. Transmission,Spot $48.326.01 1212 812055 Oswego - Lafayette 345 $54,048.24 976 36,400 812060 Dewitt-Lafayette 345 $525.62 15 200 812137 Curtis St. Tap 115 $19,553.08 320 13,600 812169 Clat - Teall 115 $525.63 15 400 812189 Teall - Dewitt #4 115 $2,335.98 60 3,000 Mortimer - Longbrach 812210 #1&2 115 $7,448.56 124 10,000 812409 Teall - Cicero 115 $955.69 27 500 812433 Woodard - Teall 34.5 $2,516.94 65 500 812444 Minoa - Chittenango 34.5 $2,408.33 68 1,200 812517 Chittenango-Rathbum 34.5 =

$3,716.56 105 .

5,000

$94,034.63 1,775 70,800 $7,013

2002 Transmission Floor Schedule Nortbern Region Line Brush Arces Complete Lake Colby-Lake Placid 94.1 812237 Mclntyre-Colton 393.6 812112 Raymondville-Norfolk 19.5 812129 Lyons Fall Paper Tap 13.9 812131 Burrows Paper Company Tap 50.3 812132 MEP cogen-Alcoa 18.2 812210 Franklin St.-Malone 5.1 812489 Ft. Covington-Spencers Corr. 42.7 812487 Nicholville-Brasher 71.2 812418 Spencers Corr.-Malone 42.1 812490 State SL-ATC 8.5 812720 Norfolk-Norwood 28.5 812785 Tap to East Norfolk 4.1 812754 Barrett Tap State St.-Little River 15.9 812721 Tap to Carthage Mills 3.2 812793 Northem cost: manhours edgeodistance S/mile

, I Misc. Transmission, 812000 Spot 9880.26 240 812130 Lowville - Boonville I 23 $4,986.12 40 2,000 812112 Mclntye - Coltonf 115 $2,515.20 60 700 812191 Malone - Lake Colby ' 115: $4,938.93 120 2,000 812237 L. Colby - L Placid 115 $17,137.00 480 14,400 -

Union - Au Sable 812328 Forks 46 $10,820.64 210 16,000 L. Clear - Tupper L. . . , r .

812332 #38 46 $39,219.17 950 30,000 Spencers Cor. -

812490 Malone 46 $4,393.58 120 _2,600 812774 High-Falls Tap 23 $15,598.49 314 7,440 c

$99,609.13 2,294 75,140 $$6,999

2002 Transmission Floor Schedule Frontier Region Line Completed Brush Acres Gardenville - Dunkirk #73,74 274 712004 Adams- Packard #183,184 14.9 712100 Adams - Packard #187,188 21 712101 Packard - Huntley #129 144 Tonawanda Tap Berhgoltz Tap 712201 Parkard - Union carbide #182 23.4 NITEC Tap Union Carbide Tap Hooker Chemical tap 712205 Huntley - Military #26H 6.8 712710 Tonawanda Lines #601 26.9 Station 79 Taps Station 77 Taps 712741 Total 511 Frontier Danger Trees cost manhours edge distance - S$mile Line No. Voltage trees Beck - Packard 76 230 $776.56 20 200 712004 Gardenville - Dunkirk 73, 74 115 $3,073.69 80 2,095 -

712008 Packard - Huntley 77,78 115 * $6,564.74

106 650 712139 Gardenville - Dunkirk 141 115 $65.87 0 60 712140 Gardenvill - Homer Hill 151 115 $62,996.45 1,160 21,470 712141 Gardenville - Seneca 81. 115 $7,117.30 110 200 712143 Niagara - Lockport 101 115 $7,782.89 154 3,160 712201 Packard - Huntley 129 115 $29,487.87 748 31,874 712205 Packard - Union Carbide 182 115 $3,404.70 60 1,000 712271 Gardenville - Republic 145 115 $696.80 16 75 712333 Lockport Taps 92 69 $4,613.99 70 475 712475 Ransornvill - Phillips 402 34.5 $34,404.26 676 18,600 712517 Youngstown - Sanbome 403 34.5 $17,174.11 322 4,462 712538 Sta. 124 - Youngman 605 34.5 $4,292.95 116 2,600 712732 Tonawanda Lines East 622 - 12 $3,106.22 80 1,000 712741 Tonawanda Lines 601 23 $17,396.34 452 15,809 712790 Kenmore - SUNY Buffalo 630 23 =

$3,259.31 84 920

$206,214.05 4,254 104,650 $10,404

2002 Transmission Floor Schedule Genesee Region Line Completed Brush Acres Attica - No. Leroy #208 68.9 712359 Attica - Wcthersfield #209 26.8 712360 Batavia - Attica #206 49.3 712362 Batavia - No. Leroy #223 52.1 712365 No. Leroy - Caledonia #203 7 Dolomite Tap 712453 total 204.1 Genesee Danger Tress - cost manhours edge distance. Slmle 712232 York Ctr. - Golah 116 115 $15,067.74 262 6,640 712256 Mortimer - Golah 110 115 $12,888.59 240 6,400 712312 Mortimer - Golah 109 69 $11,985.54 230 4,000 712338 Lockport - Batavia 112 115 $8,242.48 140 1,150 712359 Attica - North Leroy 208 34.5 $18,067.03 440 10,180 712360 Attica - Wethersfield 209 34.5 $12,577.58 312 3,930 712362 Batavia - Attica 206 34.5 $651.52 16 300 712365 Batavia - N6rth Leroy 223 34.5. $2,416.56 62 1,215 712412 Golah - North Lakeville 217 34.5 $757.92 16 75 712442 North Akron - Attica 225 34.5 $38,710.09 692 18,065 North Lakeville -

712451 Richmond 224 34.5 $776.45 16 250 North Leroy -

712453 Caledonia 203 34.5 $772.64 20 435 712532 Caledonia - Golah 213 34.5 $28,040.55 - 498 13,430 a

$150,954.69 2,944. 66,070 $12,064

ML.

2002 Transmission Floor Schedule Southwest Region Line - Completed Brush Acres Homer city- Stolle Rd #37 684.4 712060 Valley - Ischua #158 97.8 712279 Falconer- Homer Hill #153,154 205 712132 Ashville - Dow #864 67 712358 Dake Hill - Machias #803 67.5 Inc Nuclear fuels tap 712388 Delevan - Machias#801 38.1 Farmersville Tap 712390 Dunkirk - W. Portland#851 58.1 712395 Hartfield - Sherman #855 26 712419 No. Ashford - Nuclear fuels #817 13.7 712447 Homer Hill - W. Salamanca #805 118.4 712513 W. Portland - Hartfield #866 28.9 712509 W. Portland - Sherman #867 73.6 712510 Total 1478.5 edge Southwest Danger Trees cost manhours distance $Iml~e 712122 Dunkirk - Falconer 160 115 $3,751.24 20 2,500 Falconer- Homer 712132 Hill 153 115 $36,319.71 590 6,354 Gardenville -

712139 Dunkirk 141 115 $787.76 24 100 712358 Ashville - Falconer 869 34.5 $121,329.13 1,896 50,257 Cold Spr -

712384 Salamanaca 804 34.5 S51,370.95 919 13,200 712388 Dake Hill - Machias 803 34.5 $95,788.96 1.720 28,335 712390 Delevan - Machias 801 34.5 $5,690.66 144 4,140 Dunkirk - West 712395 Portland 851 34.5 $9,351.25 234 5,000 712400 Falconer- Poland 865 34.5 $3,723.93 80 0 712417 Hartfleld - Ashvile 854 34.5 $2,188.06 48 0 712418 Hartfield - Falconer 859 34.5 $2,552.15 60 150 712419 Hartlield - Sherman 855 34.5 $9,245.07 240 6,226 N. ashford - Nuclear 712447 Fuels 817 34.5 $1,264.59 32 680 712461 Olean- Ceres 809 34.5 $872.80 24 150 W.Portland -

712509 Hartfield 866 34.5 $15,141.49 265 9,400 W.Portland -

712510 Sherman 867 34.5 $11,179.45 304 13,335 Homer Hill - W.

712513 Salamanca 805 34.! $148,938.04 2.813 37,525

- =

$519,495.24 9,413 177,352 a $15,466

2002 Transmission Danger Tree Completions West Cost manhours edge distance $Smile Danger Trees Frontier Une No. Voltage 712001 Beck- Packard 76 230' $776.56 20 200 712004 Gardenville - Dunkirk 73,74 115, $3,073.69 80 2,095 712008 Packard - Huntley 77.78 115 $6,564.74 106 -650 712139 Gardenville - Dunkirk 141 115 $65.87 0 60.

712140 Gardenvill - Homer Hill 151 115 $62,996.45 1,160 21,470 712141 Gardenville - Seneca 81 115 $7,117.30 110 200 712143 Niagara - Lockport 101 115 $7,782.89 154 3,160 712201 Packard - Huntley 129 115 $29,487.87 748 31,874 712205 Packard - Union Carbide 182 115 $3,404.70 60 .1,000 712271 Gardenville - Republic 145 115 $696.80 16 75 712333 Lockport Taps 92 69 $4,613.99 70 475 712475 Ransomvill - Phillips 402 34.5- $34,404.26 ' 676 18,600 712517 Youngstown - Sanbome 403 34.5 $17,174.11 322 4,462 712538 Sta. 124 - Youngman 605 34.5 $4,292.95 116 2,600 712732 Tonawanda Unes East 622 12 $3,106.22 80 -1,000 712741 Tonawanda Unes 601 23 $17,396.34 452 ,15,809 712790 Kenmore - SUNY Buffalo 630 23 $3.259.31 84 - 920

$206,214.05

=

104,650 4,254 . 104,650 $10,404 Genesee 712232 York Ctr. - Golah 116 115 $15,067.74 262 6,640 712256 Mortimer - Golah 110 115 $12,888.59 240 6,400 712312 Mortimer - Golah 109 69 $11,985.54 230 4,000 712338 Lockport - Batavia 112 115 $8,242.48 140 1,150 712359 Attica - North Leroy 208 :34.5 $18,067.03 440 10,180 712360 Attica -Wethersfield 209 34.5 512,577.58 312 3,930 712362 Batavia- Attica 206 34.5 $651.52 16 300 712365 Batavia - North Leroy 223 34.5 $2,416.56 62 1,215 712412 Golah - North Lakeville 217 34.5 $757.92 16 75 712442 North Akron - Attica 225 34.5 $38,710.09 692 18,065 712451 North Lakeville- Richmond 224 34.5 $776.45 16 250 712453 North Leroy - Caledonia 203 34.5 $772.64 20 435 712532 Caledonia - Golah 213 34.5 $28,040.55 498 13,430

=

$150,954.69 2,944 66,070 $12,064 Southwest 712122 Dunkirk - Falconer 160 115 $3,751.24 20 2,500 712132 Falconer - Homer Hill 153 115 $36,319.71 590 6,354 712139 Gardenville - Dunkirk 141 115 $787.76 24 100 712358 Ashville - Falconer 869 34.5 $121,329.13 1,896 .50,257 712384 Cold Spr.- Salamanaca 804 34.5 $51,370.95 919 13,200 712388 Dake Hill - Machias 803 34.5 $95,788.96 1,720 28,335 712390 Delevan - Machias 801 34.5 $5,690.66 144 4,140 712395 Dunkirk - West Portland 851 34.5 $9,351.25 234 5,000 712400 Falconer- Poland 865 34.5 $3,723.93 80 0 712417 Hartfield - Ashville 854 34.5 $2,188.06 48 0 712418 Hartfield - Falconer 859 34.5 $2,552.15 60 150 712419 Hartfield - Sherman 855 34.5 $9,245.07 240 6,226 712447 N. ashford - Nuclear Fuels 817 34.5 $1,264.59 32 680 712461 Olean - Ceres 809 34.5 $872.80 24 150 712509 W.Portland - Hartfield 866 34.5 $15,141.49 265 9,400 712510 W.Portland - Sherman 867, 34.5 $11,179.45 304 13,335 712513 Homer Hill - W. Salamanca 805 34.5 $148,938.04 2.813 37,525

$519,495.24 9,413 177,352 $15,466 Total West $876,663.98 16,611 348,072 $13,298

Mowing 712004 Gardenville - Dunkirk 73,74 115 $5,236.15 116 712005 Huntley - Gardenville 79,80 115 $3,922.29 80 712006 Niagara' Packard 61 230 $7,297.08 101 712008 Packard - Huntley 77,78 230 $10,126.40 200 712100 Adams- Packard 183.184 115 $723.90 10 712110 BerholtzTaps 115 $830.00 10 712139 Gardenville- Dunkirk 141 115 $1,794.37 46 712140 Gardenville - Homer Hill 151 115 $2,727.18 22 712189 Mountain - Niagara 121 115 $2,316.48 32 712201 Packard - Huntley 129 115 $15,247.61 286 712205 Packard - Union Carbide 182 115 $4,053.84 56 712248 Ellicott Jct. - Getzville 36 23 $18,254.39 361 712741 Tonawanda Lines 601 23 $5,623.66 118 712178 Lockport - Mortimer 111 115 $5,032.79 70 712183 Mortimer- Elbridge 1.2 115 $2,795.60 40 712229 Ludwig - Depew 54 12 $1.858.85 33 712458 Oakfield - Batavia 219 34.5 $689.90 10 712003 Dunkirk- Erie 68 230 $3,656.73 74 712005 Huntley - Gardenville 79,80 115 $53,601.55 1.172 712121 Dunkirk- Falconer 161 115 $2,468.50 46 712122 Dunkirk- Falconer 160 115 $599.41 12 712132 Falconer - Hlomer Hill 153 115 $20,195.97 336 712231 Willowbrook - Brigham 164 115 $226.58 4 712358 Ashville - Falconer 869 34.5 $5,941.27 80 712513 Homer Hill - W. Salamanca 805 34.5 $3.611.05 54

$178,831.55 3,369 Access Roads 712140 Gardenville - Homer Hill 151 115 $6,885.42 80 712338 Lockport - Batavia 112 115 $18,779.37 96

$25,664.79 176

0 T . i rs Dne T CompletIon 2002 Transmission.Danger Tree Completions Central Voitage cost manhours edge distance Stmile 812000 Misc. TransmissionSpot 48326.01 1212 812055 Oswego - Lafayette 345 $54,04824 976 36,400 812060 Dewitt-Lafayette 345 $525.62 15 200 812137 Curtis SL-Tap 115 $19,553.08. 320 13,600 812169 Clat-Teall 115 $525.63 15 400 812189 Teall - Dewitt #4 115 7 $2,335.98 60 3,000 812210 Mortimer- Longbrach #1&2 115 $7,448.56 124 10,000 812409 Teall - Cicero 115 $955.69 27 - 500 812433 Woodard - Teall 34.5 $2,516.94 65 ;500 812444 Minoa - Chittenango 34.5 $2,408.33 68 1,200 812517 Chittenango-Rathbum 34.5

$94,034.63 1,775 70,800 $7,013 Mohawk : .-

812000 Misc. Transmission, Spot $16,271.82 440 812001 Adirondack - Porter 230 $75,333.00 1,292 39,406 812004 Porter - Rotterdam 230 $55,782.84 1,192 80,300 812161 Boonville;- Porter 115 $3,209.82 60 2,000 812164 Porter - Schuyler 115 $11,339.52 240 - 5,000 812346 Schuyler.-Valley 46 $18,976.70 420 6,500 812372 Valley - Inghams #24 46 $33,276.40 740 45,000 812379 Old Forge - Raquette L. 46 $11,722.85 246 3,000

$209,641.13 4,190 181,206 $6,109 Northern cost .manhours edge distance *Imile 812000 Misc. Transmission, Spot 988026 240 812130 Lowville - Boonville 23 $4,986.12 40 2,000 812112 Mclntye - Colton 115 $2,515.20 60 700 812191 Malone -Lake Colby 115 $4,938.93 120 2,000 812237 L Colby- L. Placid 115 $17,137.00 480 14,400 812328 Union - Au Sable Forks 46 $10,820.64 210 16,000 812332 L. Clear- Tupper L. #38

46 $39,219.17 950 30,000 812490 Spencers Cor. - Malone - 46 $4,393.58 120 2,600 812774 High Falls Tap 23 * $15,598.49 314 7,440

$99,609.13 2,294 75,140 $6,999 Total Central $403,284.89 8,259 327,146 $6,509 Mowing 812055 Oswego - Lafayette 345 $5,768.28 100 812186 Oswego- Nine Mile 345 $4,474.43 80 812000 Misc. switches $2,898.48 80 812181 Rome-Levitt 115 $2,534.81 40

$15,676.00 300 Access Roads 812003 Porter - Rotterdam 230 $741.60 15

$741.60 15

I K_

2002 Transmission Danger Tree Completions East Voltage cost manhours edge distance smnile Danger Trees Capital 900112 Misc. Transmissionspot $52,180.32 1,317 912020 Spier - Rotterdam 115 $11,837.41 260 5,400 912104 Porter- Rotterdam 230 $47,726.78 804 31,612 912157 Maplewood - Menands 34.5 $7,215.16 150 1,400 912222 Greenbush - Stephentown 115 $61,991.90 1,216 64,511 912295 North Troy - Hoosick 115 $14,354.32 312 2,700 912344 Renolds Rd. - Alps 345 $59.436.87 1,200 57.455

$202,562.44 3,942 163,078 $6,558 Northeast 912000 Misc. Transmission,Spot $1,083.98 30 912051 Mohican-Whitehall 115 $18,973.97 410 2,400 912072 White Hall - iconderoga 115 $10,308.31 192 3,730 912294 North Creek - Indian Lk. 34.5 $198,028.74 3.518 62.956

$227,311.02 4,120 69,086 $17,373 Total East $429,873.46 8,062 232,164 $9,776 Access Roads System Totals Danger Trees $1,709,822.33 32,932 907,382 $9,949 Mowing $194,507.55 3,669 Access Roads - - $26,406.39 191 Totals $1.930.736.27 36,792 907,382

2002 New York Transmission Vegetation Management Expenditures Expenditures on Substation Vegetation Control Region Amount

';apital $45,511.94 Northeast $26.219.56 MohawkV $21,981.66 Central $60.075.60 Northern - $20,710.84 Frontier $53,586.12 Genesee $0.00 Southwest $1.473.84 Total $229,559.56

. A.

a-National Grid National Grid Transmission USA New York Right-of-Way Management Adirondack Rights-of-Way Maintenance 2002 Region Line Voltage Total Low Hyd. Low Cut, Cut, Cut, Cut, No Trim KV Brush Volume Volume Stump Stump Stump Treat Acres Foliar Foliar Treat Treat, Treat, Windrow Chip i North Lake 115 94.1 9.9 0 58.8 1 2.6 21 .8 Colby-Lake

_ _Placid ______ _

- . , National Grid National Grid Transmission USA New York Access Roads, Fences, Gates and Misc. Restorations 2002 In 2002, the restoration and access road work addressed various scattered incidents,- with a total expenditure of $31,106.39, as follows:

Western Division: Total: $25,664.79 Gardenville - Homer Hill Lockport - Batavia Central Division: Total: $5441.60 Malone - Lake Colby - 115kV Clay - Dewitt 345kV Edic - New Scotland 345kV Eastern Division: Total: $000.00

Transmision IVM Program 2003 Schedule Capital Region Brush Acres Right-of-Way PR# kV Scheduled Complete New Scotland - Alps 912333 345 533.6 Greenbush - Stephentown 912222 115 67.4 North Troy - Renolds Rd. 912302 115 160 Deleware - Bethleham 912319 34.5 24.9 Rensselear - Greenbush 912142 34.5 40.4 Vischers - Woodlawn 912184 34.5 33.6 Woodlawn - Kamer 912213 34.5 19.6 879.5

Transmissior ilVM Progra , -ni 2003 Schedule Northeast Region Brush Acres Right-of-Way PR# kV - Schedulece Cormplete Inghams - Colliers 912033 .115 101:.5 Spier - Queensbury 912316 :115 125.9 Sherman Island Tap included Ogden Brook Tap included Spier- Rotterdam 912020 115 469.2 Brook Rd. Tap included Weibel Tap included West Milton Tap included Ballston Tap included Malta Tap included St. Johnsville - Marshville 912322 115 34.9 Chariton - Ballston 912180 34.5 54.9 West Milton Tap included Henry St. - Glens Falls 912029 34.5 7 South Glens Falls Tap included Crown Zellerbach included 793.4

Transmission IVM Program 2003 Schedule Mohawk Valley Region Brush Acres Right-of-Way PR# kV Scheduled Complete Edic - Porter 812001 230 2.4 Porter - Rotterdam 812004 230 240.3 Boonville - Rome 812134 115 147.2 Ava Tap included Turin tap included Madison Tap included Griffiss Tap included Edic - Porter #10 812200 115 2.9 Edic - Porter #20 812239 115 5.7 Porter- Deerfield 812163 115 1.4 Dolgeville-lnghams 812376 46 11.8 New Hartford - Schuyler 812353 46 81.4 Homogeneous Metals Tap included Chicago Pneu/Sperry Tap included Old Forge-Raquette Lake 812379 46 121.6 Pleasant - Schuyler 812342 46 9.1 Charlestown Tap included Schuyler - Valley 812346 46 85 Library Bureau Tap included W. Herkimer Tap included Mohawk Muni Tap included Illion Tap included Remington Arms Tap included Frankfort Tap included Union Fork and Hoe Tap included Frankfort mine Tap included Mohawk data Serv Tap included Trenton - Deerfield 812341 46 38.6 Trenton - Prospect 812362 46 19.6 Whitesboro - New Harford 812369 46 14.2 Utica Cutlery Tap included Yahnundasis - New Hartford 812370 46 11.3 Yahnundasis - Pleasant 812364 46 24.6 Arnold Tap included Bendix Tap included 817.1

Transm'ission IVM Program 2003 Schedule*

Central Region Brush Acres Right-of-Way PR# kV - Schedulec I Complete Dewitt - Lafayette 812060 -345 151.6 Oswego - Lafayette 812005 345 573.6 Curtis street tap 812137 115 16 Budwieser/Lysander tap 812229 115 23.2 Clay - Teall #11 812169 115 142.9 Hopkins road Tap included Euclid& OCWA Taps included Crouse Hinds Tap included Teall - Onieda 812204 115 230.5 Bridgeport Tap 812166 .115 15.8 Borden tap 812403 34.5 0.5 Eureka Tap 812414 3.1 Headson - Minoa 812443 34.5 30.9 Oswego - Varrick 812500 34.5 0.7 Teall #25 Loop 812431 34.5 8.3 Teall #26 Loop 812439 34.5 14.8 Ononondaga Water Tap included Midstate Supply Tap included Court Street Tap included Syracuse China Tap 812437 Ley treatment Tap 812438 Varrick - High falls 812495 34.5 0.7 Woodard - Ash 812441 34.5 19.6 Liverpool Tap included Galeville Tap included Metro Treatment included Tie to Solvey URD included 1232.2

Transmission IVM Progra 2003 Schedule Northern Region Brush Acres Riht-of-Way PR# kV ScheduledI Complete Browns Falls- Taylorville 8121:25 115 314.6 Soft Maple- Moshier 8121:27 115 .71.6 Taylorville- Soft Maple 8121 28 115 56.4 Franklin Falls- Bloomingdale 8123 37 46 61.7 High Falls- Union Falls 8123 27 46 97.8 Lk Clear- Lk Colby 8123 34 46 43.6 Union falls- Franklin Falls 8123 29 46 81.3 Bombay- Ft Covington 8124 88 34.5 16.2 Brasher - Bombay 8124 .19 34.5 85.1 St. Regis tap includec Brownville - Frontenac 8124 72 23 15.8 Coffeen - Brownville 812777 23 15 Brownville Mills tap 859.1

Transmission IVM Program 2003 Schedule Frontier Region Brush Acres Right-of-Way PR# kV Scheduled Complete Beck - Packard #76 7120 01 230 41.3 TAM Taps 71V? 23 11.5 35.9 Packard - Huntley #77,78 7120 08 230 214.4 Adams - Packard #183,184 7121 00 115 3.2 Airco Speer Tap included Olin Corp. Tap included Adams - Packard #187,188 7121 01 115 5 Gardenville - Homer Hill #151,152 7121. 40 115 273 Phillips - Telegraph #304 7124 71 34.5 South Newfane Tap included 9.8 RPamsomville-Phillips #402 7124 75 34.5 35.3 Youngstown - Sanbome #403 7125 17 34.5 32.8 650.7

K-Transmission IVM Program 2003 Schedule Genesee Region .

Brush Acres Right-of-Way PR# kV Scheduled Complete Batavia-Golah #117,119 712255 115 239.9 Lapp Tap included East Batavia Tap included Oatka Tap included S.E. Batavia Sattion included 239.9

Transmission IVM Program 2003 Schedule Southwest Region Brush Acres Right-of-Way PR# kV Scheduled Complete Dunkirk - Falconer #160 7121, 22 115 348 Columbia Gas Tap included Cummings Eng. Tap incl;uded Baker St. Tap included Falconer - Homer Hill #153,154 712132 115 170 Willowbrook - Brigham #164 712231 115 6 Hartfield - Ashville #854 712417 34.5 33 Hartfield - falconer #859 712418 34.5 100 Machias - Maplehurst #802 712435 34.5 80.1 Buffalo Slag Tap 712372 34.5 So. Wellsville - Andover #541 712489 34.5 45.3 Preheater Tap included Whitesville Tap included 782.4

APPENDIX 11 Nia @MOAhW Aa I XI EG-504 I No. 0 PAGE 1F ENVIRONMENTAL GUIDANCE DAoE0 DATE 08/01101 SUBJECT SECTION Pesticide and Herbicide Application Transmission & Distribution SCOPE This guidance document covers the NYSDEC environmental regulatory requirements associated with the use of pesticides and herbicides by NMPC personnel and contractors hired by the Company.

GENERAL In the course of its day-to-day business operations, NMPC engages in the use of pesticides, herbicides and/or biocides. Such uses may include:

Controlling undesirable vegetation along electric and gas line rights-of-ways.

. Controlling undesirable vegetation at substations, gas regulator stations, and other NMPC facilities.

Controlling pests that may pose a threat to worker safety and/or facility integrity and reliability.

Pesticide uses are regulated by the New York State Department of Environmental Conservation (NYSDEC) as set forth in the applicable parts of Title 6, NYCRR including Part 320 - Pesticides - General, Part 325 - Application of Pesticides, and Part 326 - Registration and Classification of Pesticides.

GUIDANCE What is a Pesticide?

As defined by NYSDEC, a "pesticide" is any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any insects, rodents, fungi, weeds, or other forms of plant or animal life or viruses and any substance or mixture of substances intended as a plant regulator, defoliant, or desiccant. Pesticides include such things as herbicides, biocides, etc.

How is NMPC regulated?

By NYSDEC definition, NMPC is regulated as an "agency" and not as a commercial lawn applicator. As such, NMPC is subject to NYSDEC regulations regarding the use of pesticides, disposal of pesticides and pesticide containers, employee training and safety, pesticide applicator certification, business registration, reporting of pesticide use, pesticide product registration, and pesticide spill response and clean up.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document from the Intranet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy, refer to the Intranet or controlled EG Manual version.

Niaram M wk NO1 E504 0 PAGE 2F ENVIRONMENTAL GUIDANCE DATE 08/01/01 SUBJECT SECTION Pesticide and Herbicide Application Transmission & Distribution Requirements for the Use of Pesticides Pesticides are to be used only in accordance with label and labeling directions and must be used in such manner and under such wind and other conditions as to prevent contamination of people, pets, fish, wildlife, crops, property, structures, lands, pasturage or waters adjacent to the area of use. During pesticide use, the certified applicator, certified technician or commercial pesticide apprentice must have access to a copy of the label for each pesticide being used and must make each label available for inspection upon request of the NYSDEC.

Cleansing and Disposal of Pesticides and Containers Generally, empty pesticide containers may be disposed of in an approved sanitary landfill after they are properly rinsed and cleansed. Returnable containers must be tightly closed to prevent leakage, the exterior cleaned, and the containers returned to the supplier.

Unwanted or unusable pesticides may be subject to more stringent disposal requirements including EPA and DEC hazardous waste disposal regulations. The Environmental Affairs Department should be contacted to coordinate the removal and disposal of any unwanted or unused herbicides. See EG-100 for additional guidance.

Training and Safety Prior to any pesticide application, a certified pesticide applicator must provide safety information and training to individuals using pesticides.

Applicator Certification Requirements The application of pesticides must be accomplished by, or under the supervision of, a certified commercial pesticide applicator certified pursuant to NYSDEC requirements. The certified commercial pesticide applicator must posses a valid identification card issued by the NYSDEC and make such card available upon request. Full certification is not required for "technicians" and "apprentices" who meet the requirements set forth in 6 NYCRR, Part 325 and are using pesticides under the on-site or off-site direct supervision of a certified commercial pesticide applicator as defined in the Part 325 regulations.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document from the Intranet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy.

refer to the Intranet or controlled EG Manual version.

lh EG-504 Rev.

ENVIRONMENTAL GUIDANCE No.

DATE 08/01/01 SUBJECT SECTION Pesticide and Herbicide Application Transmission & Distribution Business Registration As an agency that applies pesticides, NMPC is required to register annually with the NYSDEC. In addition, NYSDEC regulations require that NMPC have at least one employee who is a certified commercial pesticide applicator or technician.

Reports Annual reports, listing the quantities of each pesticide used by NMPC personnel during the previous calendar year, are to be filed by NMPC Forestry personnel with the NYSDEC by February 1 of each year.

Contractors hired by NMPC to apply pesticides are required to file their own reports. Copies of reports and appropriate pesticide use records shall be maintained by the Forestry Department for a period not less than three years.

Pesticide Product Registration All pesticides used by NMPC, or under contract to NMPC, must be registered by both the EPA and the NYSDEC. Any such pesticide will contain the EPA registration number on the label.

Spills Herbicide spills of any quantity should be reported to the Environmental Affairs Department immediately to determine if a reportable quantity spill threshold has been exceeded. Depending on the specific herbicide spilled regulatory agency notification may also be required. Refer to EG-202 for detailed guidance on herbicide spill reporting and EG-100 for additional guidance on herbicide spill cleanup requirements.

Public Service Commission Requirements NMPC's System Forestry Department is the primary pesticide user with the Company having responsibility for vegetation management of thousands of acres of transmission and distribution rights-of-way and related facilities. The management of these land holdings is subject to PSC regulation, set forth in 16 NYCRR, Part 84, which requires that NMPC prepare a detailed right-of-way management plan for PSC review APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document from the Intranet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy, refer to the Intranet or controlled EG Manual version.

==

Nia a MlNO. E504 lNo. 0 ENVIRONMENTAL GUIDANCE PAGE 40F 4 DATE 08/01/01 SUBJECT SECTION Pesticide and Herbicide Application Transmission & Distribution and approval. The PSC also requires that annual reports, summarizing right-of-way management activities for the past year and right-of-way management plans for the current year be submitted to the PSC on or about March 31 of each year. The Forestry Department is responsible to prepare and file these reports. Copies of these reports are provided to EAD.

NYSDEC Permit Requirements In addition to the requirements noted above, the NYSDEC regulates the application of pesticides within State-regulated wetlands and the 100-foot buffer zone surrounding such wetlands. Any such application of pesticides to wetland and wetland buffer zone areas requires a Freshwater Wetlands Permit from the NYSDEC and pesticide applications must conform to the conditions of the NYSDEC permit. A copy of a valid permit must be maintained in the field by the supervising certified applicator and must be available for inspection if requested.

The Environmental Affairs Department is responsible to obtain such permits and should be consulted with any questions relating to the need for permits.

CONTACTS Questions concerning the above guidance can be directed to:

System Forestry Ken Finch 821-5985 Environmental Affairs Ray Cummings 821-6613 Legal Bill Holzhauer 821-6341 REFERENCES EG-100 EG-202 6 NYCRR, Parts 320, 325,326 6 NYCRR, Part 663 16NYCRR, Part 84 Current Transmission Right-of-Way Management Program Plan (October 1989)

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document from the Intranet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy, refer to the Itranet or controlled EC Manual version. ______________

-I

Niagm %@Mohawk N EG-202 No. 3 ENVIRONMENTAL GUIDANCE PAGE Rev.

1 OF 4 DATE 10/02/00 SUBJECT SECTION Herbicide Spill Reporting Spill Reporting & Cleanup Procedures SCOPE This procedure describes the reporting of herbicide spills.

GENERAL Herbicide spills shall be reported to the regulatory agencies immediately (within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of discovery) based on the notification criteria established in this procedure.

Do not sign any forms from governmental agencies at the scene. If necessary, indicate to officials that forms must be reviewed by Niagara Mohawk's Law Department. Send the forms to the Chief Counsel Environmental Affairs for review.

NOTIFICATION CRITERIA The following spills shall be reported as a herbicide spill:

Whenever any of the following herbicide concentrates or mixtures (mixed spray as'opposed to concentrate) are spilled either into water or onto land in a quantity exceeding the amounts shown below:

Herbicide Concentrate Amount Amount of Mixture Reportable Hazardous (In Gallons) (In Gallons) Substances (RO)

Garlon 3A 30 6,500 Triethylamine (100 lbs.)

Pathway* 50 2,4,D (100 lbs.)

Tordon RTU* 50 2,4,D (100 lbs.)

Tordon 101 50 10,000 2,4,D (100 lbs.)

Tordon lOlR* 50 2,4,D (100 lbs.)

Weedone CB 150 168 2,4,D (100 lbs.)

Ready mixed NOTE: The above list is being revised; if you have a herbicide spill of any quantity you should call Environmental Affairs to determine if a reportable quantity has been exceeded.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this docurent from the ntanet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy, refer to the Intranet or controlled EG Manual version.

Niagzam ark~fi\A EG-202 l No. 3 Nia~1ra ENVIRONMENTAL GUIDANCE o

DOC PAGE 2 OF 4 Rv DATE 10/OVOO SUBJECT SECTION Herbicide Spill Reporting Spill Reporting & Cleanup Procedures PROCEDURE 1. Notification shall be made immediately to the Regional Control Regional Field Center or Trouble Office after discovery of spill. The notification Personnel Reporting will include all information listed on the Report on Spills (EG-201, of Spill Form #323-086) and will be provided to the appropriate offices listed below:

For releases which result in exposure to persons outside the boundaries of an NM facility, refer to Corporate Environmental Guidance EG-206

- SARA Title III. Contact the Corporate Environmental Affairs Department or the designated SARA Title III individual (as applicable) for information.

EAST Regional Control Center - Altamont (518) 356-6471 CENTRAL Central Region Operations - Syracuse (315) 460-2421 WEST Dewey Avenue Trouble Office - Buffalo (716) 831-7325 NUCLEAR Station Shift Supervisor on duty - Nine Mile Unit I - (315) 349-2478 UnitII - (315) 349-2170 The Nuclear Station Shift Supervisor notifies the Nuclear Environmental Protection Department which performs the notifications.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this docunent from the hItranet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy, refer to the Intranet or controlled EG Manual version.

N ~

Ni.Iak1 \M0nIeDOC -- lgm%'V NO. EG-202 I No. 3 ENVIRONMENTAL GUIDANCE PAGE DATE 3 OF4 10/02/00 SUBJECT SECTION Herbicide Spill Reporting Spill Reporting & Cleanup Procedures Regional Control Shift 1. The Shift Supervisor shall take the following action and Notifies Supervisor - Reporting the following agencies immediately:

of Spill

a. New York State Department of Environmental Conservation at 1-800457-7362.

b. National Response Center at 1-800-424-8802-

c. If the Reportable Quantity is exceeded the LEPC has to be notified (see EG-206)

2. Provides agencies with the information they request from the Report on Spills (Form 323-086).

3. The Regional Shift Supervisor shall use his best judgement on deciding whether or not a spill is of a highly sensitive or serious nature (from a possible public exposure, environmental, or public relations point-of-view) such as those involving surface water bodies and/or public highway corridors. The Regional Shift Supervisor shall also notify Company Personnel as appropriate that are listed below:

. Public Affairs and Comorate Communications - Notify respective Regional Directors

System Safety Department - Notify respective divisional Safety Managers

. Legal/Corporate Relations - Notify respective divisional Managing Counsel (Environmental)

System Security - Notify respective divisional Security Supervisors

Risk Mananement - Notify respective divisional Supervisor Claims

Facilities Management - Notify respective divisional Manager Facilities

4. If an outside cleanup contractor is necessary, contact the Divisional Environmental Facilitator.

5. If technical assistance is required contact the Divisional Environmental Facilitator or the Environmental Affairs Department personnel listed in EG-800.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document from the Intranet or copies made fiom the EG Manual are not controlled and will not be updated. For the latest approved copy, refer to the Intranet or controlled EG Manual version.

NiagNra Mollawlc NO. E202 lR 3 ENVIRONMENTAL GUIDANCE PAGE DATE 10/02/00 SUBJECT SECTION Herbicide Spill Reporting Spill Reporting & Cleanup Procedures

6. Log and document the spill on the Report on Spills, Form #323-086, located in EG-201). Include all pertinent information and include a photograph if possible. Send or fax copy of Report on Spills form to:

a. Environmental Affairs Department

b. Divisional Environmental Facilitator

c. System Electric Operations

d. System Forestry Department Disposal For Disposal of spill debris, see EG-I00 Spill Cleanup Contact the Divisional Environmental Facilitator, Environmental Affairs Department, or at the Nuclear Stations the Environmental contact for assistance. Refer to EG-800 for the appropriate contacts.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document from the Intranet or copies made from the EG Manual are not controlled and will not be updated. For the latest approved copy.

refer to the Intranet or controlled EG Manual version.

DOC Nig1NA~ W NOk~l~ . G-0 e.1 Noo

- EVIRONWENTAL GUIDANCE PAGE 1OF4

. DATE 100/0/0 SUBJECT DumpSECTION & Drt Unauthorized Dumping,-Tasiso itbto INTRODUCTION Unauthorized Dumping / Contamination on NMPC Rights-of-Way and I

Other Properties may pose a threat t 0The environment or be in violation of environmental, regulations. This guidance document provides information on what to'do in the event of dumping on a NM right of way.

BACKGROUND There have had a number of inquiries from the field concerning instances of potential environmental contamination and/or unauthorized or illegal dumping on Company electric and gas rights-of-way or other NMPC-owned prope'rties While many of these instances are more of a nuisance in nature,'sever of the recent inquiries have alerted us to the potential for "these activities to cause adverse environmental contamination or other impacts to our properties. *When instances are identified that may pose a threat to the enivironment or be'in violation of environmental regulations, prompt' internal'communication and appropriate action should take place to correct .the problemrn and, if applicable, advise affected external regulatory agencies of the problem and corresponding Company action.

The following guidance is provided to assist you in identifying those activities that may cause a threat to the environment and initiating appropriate action to report and, if necessary, correct the situation.

IDENTFLIABLE The most important concerns are those that cause or have the potential CONCERNS to cause an. immediate adverse impact to the environment. Also important are materials that may not necessarily pose an environmental threat, but are required by State and/or Federal laws to be disposed of at approved and licensed facilities. Examples of materials or situations Ithat could cause'an environmental threat or violation include (but are not linited to). '

Trash, garbage and/or rubbish

-* Construction and demolition debris Tires '

Roofing material

Foundry sand

Utility poles ,

Driveway sealant

PCB containing oil

' Gasline, motor oil, hydraulic fluid, brake fluid, and other oils, oil containers or oily debris

.0 Solvents, sealers, cleaners, degreasers, paint, paint thinners, varnish, pesticides, and other similar chemicals APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT .

Printed copies of this document from the Intranet or copies made from the EG Manual am not controlled and will nOt be updated. For the latest approved copy.

rfer to the Intranct or controlled EG Manual versio -n'

U

~v~ mDOC Rev. 1 Niag n ~- ~

i NO. EG-502 No.

I ENVIRONMENTAL GUIDANCE PAGE 20F4 DATE 10102100 .

SUBJECT SECTION Unauthorized Dumping Transmission & Distribution'

Refrigerators

Batten'es

Mercury or sodium vapor bulbs and related debris

. TLighting ballasts and spent fluorescent bulbs

Thermostats

Asbestos debris

'* Flammable or ignitable substances

Any type of container or drum which could contain residue or quantities of any of the above materials or unknown materials

Any other material which may have the potential to cause an adverse environmental impact

Any material which has been deposited in or within 50 feet of a stream or other waterbody

Any material which has been deposited in or within 100 feet of a Federal or State wetland

Abandoned motor vehicles GUIDANCE If. you see or become aware of any situation potentially involving the Identifiable Concerns listed above on NMPC rights-of-way or other NMPC property or any'other situations of potential environmental contamination, please: follow the steps listed below.

1. Gather Information - Note the time, date, and location of the incident; a 'description of the problem; type of material or contamination found;' and any immediate action taken. A sketch, map and photos of the affected area would be helpful.

2. Immediately Call Your Reirional Sect rity Representative and Report the Situation - Security Contacts as Follows:

Corporate 821-5135 315 428-5135 Central 821-6163 315 428-6163 East 831-5925 518 433-5925 West 841-4354 716 8574354 Central - Emergency 821-5100 315 428-5100 APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of this document froa the Intanct or copies made fom the EG Manual am not controlled and will not be updaxd. For the latest approved copy.

refer to the Intranet or controlled EG Manual vernion.

"N DNO.C EG-502

~ -~ - ENVIRONMENTAL GUIDANCE PAGE 3 OF 4 DATE 10/02100 SUBJECT SECTION' Unauthorized Dumping Transmission & Distribution West-Emergency - 841-7134 716 831-7134

- Your Security Department representative will request the information listed in item 1 above and any additional information deemed

- appropriate.

3. Immediately call William J. Holzhauer, Chief Counsel Environmental Affairs, at (315) 428-6341.

4. The Law Department will Notify the Environmental Affairs Department if the Incident Poses an Immediate or Potential Threat to the Environment and/or may be Considered as an*

Illegal or Unauthorized Dumping Activity.

The Law Department is responsible to contact the Environmental Affairs Department using the above list of Identifiable Concerns and their professional judgement as a guide. The primary EAD contacts are as follows:

I Activity Contact Tie Line Outside Phone Matters Affecting Ray Cummings 821-6613 (315) 428-6613 NMPC Rights-of- Scott Shupe 821-6616 (315) 428-6616 Way All Other Matters . Chris Read 821-3631 (315) 428-3631 Affecting Non- Bob Cazzolli 821-3490 (315) 428-3490 ROW Company Properties _ __ _ __ .___

5. Environmental/Law Enforcement Aencv Notification The EAD representative, in consultation with the Law Department, will review the information concerning the incident and determine whether or not it is appropriate to notify the New York. State Department of Environmental Conservation or any other environmental regulatory agency. The Security Department representative will determine whether or not it is appropriate to notify law enforcement authorities.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT- -

Printed copies of this docunent from the Intranct or copies made from the EG Manual am nottrolnfled and will W be updated. For the lest approved copy.

refer to die Intranet or controlled EG Manual version.

riagr' m . . NO.DOC EG-502 -I Nev. .

N 1l ENVIRONMENTAL GUIDANCE PAGE 4 OFRiv.41 DATE 10O0200I SUBJECT SECUION Unauthorized Duimping Transmission & Distribution

6. Follow up - The EAD, Law and Security Departments will, with your assistance, coordinate any necessary follow up, including cleanup if required, to resolve the problem and will keep other NMPC departments apprised of the situation. The Corporate Safety & Health Department will provide guidance on personal protective equipment to be worn by NMPC employees, if cleanup is required. All follow-up activities will be documented by the involved EAD and Security Department personnel.

APPROVED BY: VICE PRESIDENT - ENVIRONMENTAL AFFAIRS & PROPERTY MANAGEMENT Printed copies of dis docuzn fom the Intranet or copies made for: the EG Manual are not controlled and will not be updated. For the latest approved copy.

I

-f n .h. . o.et nrhlM] Fir Manual U vnI m,., I ..

1- - -- - -- , -- ----

APPENDIX 12 APPENDIX 8 SPECIAL PLAN CONDITIONS WHICH APPLY WITHIN THE ADIRONDACK PARK i.-

. : .., ~ . ,-

..... . i

As a result of the PSC order issued July 20, 1988 in Case 27605, NMPC is required to incorporate into its transmission right-of-way management plan certain conditions that apply only to that portion of its transmission system within the Adirondack Park. To clarify how these conditions will be incorporated into the plan, each ordering clause is repeated below, followed by a description of how NMPC's practices will be modified to comply with the requirements of the order.

Orderina Clause 1 "Niagara Mohawk Power Corporation and New York State Electric & Gas Corporation shall revise their systemwide electric transmission right-of-way management plans in accordance with the following provisions, and shall submit the revised plans for approval by the Director of our Office of Energy Conservation and Environment before November 30, 1988."

The NMPC plan has been revised by inclusion of this Appendix 8.

Orderinc Clause l.a.

"Herbicides shall not be applied by helicopter within the Adirondack Park."

The aerial spray method will not be considered as a management technique for rights-of-way within the Adirondack Park. Therefore, the discussion regarding aerial spray found on pages 40, 41-,42,'43 and the approval process described on page 73 of the :plan will be disregarded -when selecting a vegaatatioGn management technique to be utilized within the Adirondack Park.

Ordering Clause l.b.-

"Stem-foliar spraying in the Adirondack Park shall be limited to'sites with "dense" or "heavy" density of unidesirable species, or to sites with "moderate" or "medium" density of undesirable species and accompanying densities -of only "scattered" or--"light" desirable species. Stem-foliar spraying shall be limited to sites where undesirable species average less than l0' tall-and will be done only when wind speeds-are less than 10 mph."-

on pages 45 & 46 of the plan NXPC lists conditions 1,2,3 &

4 where the'stem-foliarrmethod will' be utilized. Conditions 1 and 2-describe species' densities that remain appropriate when stem-foliar method prescriptions are made within the Adirondack Park. condition 3 on page 46 will not be considered within 'the Adirondack Park. In addition, stem-foliar spraying shall be limited to sites where undesirable species average less than 10-feet in height and when wind speed is less than-io mph.

Orderincq' Clause l.c. -

"Herbicides used within 100 feet of highway traffic corridors, identified in the 1979 APA State Land Master Plan,-

shall be selected or their application timed to avoid "brown out" until after Labor Day in any year."

-IL-Herbicides that have the ability to cause brown out will not be applied by any method of application that could result in brown out more than one week prior to Labor Day within 100 feet of the shoulder of a highway right-of-way identified as a highway travel corridor in the 1979 APA State Land Master Plan.

Herbicides or herbicide application methods, not capable of.

producing brown out, are not subject to this restriction.

Ordering Clause l.d.

"Rubus spp. (blackberry, raspberry, etc.') shall be included on the. list of desirable species inventoried for right-of-way vegetation management purposes and regularly reported to staff when inventories are required."

Brambles or Rubus spp. are listed on page 33 as a compatible specie to be included in rights-of-way inventories for vegetation management purposes. Where brambles comprise one of the three major compatible species, they will be included in the inventory and reported to the PSC Staff when vegetation inventories are required.

Ordering Clause I.e.

"Herbicides shall not be used within a minimum horizontal distance of 100 feet of a potable water supply or regulated wetlands or protected waters. Buffer zones shall be maintained around other wetlands, perennial and intermittent streams, and-waterbodies as follows:"

Herbicide Application Techniirue Minimum Appr6ach Distance-stem-Foliar - 50 Feet

Basal - 30'Feet Cut-and-Stump 30 Feet Herbicides shall not be used within a minimum horizontal-distance of 100 feet of a potable water supply, regulated wetland or standing waters where the need for'herbicide buffer zones has been established by regulation pertaining to protecting waters or by specific herbicide label restrictions Herbicide buffer zones shall be maintained around other wetland, perennial and intermittent streams, and waterbodies as followsi:

Herbicide Application Technique Minimum Approach Distance Stem-Foliar 50 Feet Basal. 30 Feel

-Cut-and-Stump 30 Feet The above 'stated buff ei distances replace those found on pages 43,46 and apply for all 'rights-of-way treatments within the Adirondack Park. -

Orderinq Clause 1.-f.-

"Reasonable efforts shall be`made-to inform -persons who may.

be expected to enter areas treated with herbicides."

The universal pesticide application notification requirements of 6 NYCRR Part 325 will be followed.

Ordering Clause 2.a.b.c.

"2 Niagara Mohawk Power Corporation and New York State Electric and Gas Corporation shall initiate a study during 1988 to determine the efficacy of herbicide buffer zones, in the park and elsewhere. The study shall conform to the following. schedule and conditions: . .

on October .19, 1988 WMPC & NYBESG reviewed this part of the order with PSC Staff. Staff agreed to review both of the earlier studies completed by NKPC and NYBE&G, and set up a follow-up meeting on this subject.

Ordering Clause 3.

"Niagara Mohawk-Power Corporation and New York State' Electric & Gas Corporation shall report, to the Secretary, by March 31 of each year, the transmission right-of-way acreage.

within the Adirondack Park treated or maintained in the preceding year by each technique (using herbicides or ,not) for controlling undesirable vegetation."

NKPC will submit by March 31 of each year, to the Secretary, a report as described-in ordering clause 3 above...

.. 7, I - rs . .s as ofj -'it' ..

. <. t r.

.g1 q;x/s_ - -

l _ ~National Grid USA is committed to the protection and enhancement of the environment, ;-

always seeking new ways to minimize the environmental impacts of our past, present and future activities. We believe that everyone is responsible for good environmental per-formance as we incorporate environmental considerations into all our business activities.

-The following principles provide the framework to help us set goals to promote continual improvements in environmental performance and to deliver and maintain a culture that achieves the performance to which we aspire.

We:

4 Expect management to provide visible leadership that promotes good environmental performance and to commit the appropriate resources to achieve our environmental goals;

4 OMeet, and where appropriate, exceed the requirements of environmental legislation, policies, charters and other commitments to which we subscribe; o Prevent pollution, including the releases of oil and hazardous materials,

-awherever we can, but if an incident occurs respond effectively to minimize I . Mimpact on human health and the environment; 4 Minimize and properly manage the waste we generate, and reuse or recycle waste materials whenever economically feasible; 0 Help protect the environment for future generations by making our contribution to minimizing climate change;

, Monitor electric and magnetic fields (EMF) research developments and assess continually the implications for the way in which we operate; .

$ Manage the risks associated with sites that have been contaminated from our past operations and improve these sites where appropriate;

Protect and improve, where we can, the environmental status of the land on which we operate; .. .

(41

Require our contractors to demonstrate the same level of commitment as National Grid USA in the management of the environment; .

SAEnsure that our employees have the skills, knowledge, and resources necessary to contribute to our environmental commitments; 0 Encourage open and constructive dialogue with employees, members of the public and other stakeholders to continually challenge our performance;'

4 Identify and manage risks associated with our activities and deliver any ;

improvements through effective environmental management systems; i Monitor our environmental performance, audit the effectiveness of our management systems, and report our performance to employees, shareholders, the public and other stakeholders. ..-

t. s,;n NNational Grid XWAAN

-- ~,-,

Transmission Right-Of-Way Management Program October 1989 Prepared by:

Environmental Affairs and Transmission Forestry Departments Revised:

- November 2003 The core functions of National Grid's U.S. transmission business have achieved ISO 14001 registration of their Environmental Management System.

ML043130295

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Dear Ms. Deixler:

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