ML030140071

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Environmental Report Information for R. E. Ginna Nuclear Power Plant, Attachment 11
ML030140071
Person / Time
Site: Ginna Constellation icon.png
Issue date: 12/23/2002
From: Mecredy R
Rochester Gas & Electric Corp
To: Robert Schaaf
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML030140071 (82)


Text

ROCHESTER GAS AND EECTRIC CORPORA77ON 89 EAST AVENUE, ROCHESTER, N' 146d9-0001 AREA CODE 776 546-2700 January 25, 1995 Mr. Larry Jackson State of New York Department of Public Service Three Empire State Plaza Albany, New York 12223 Re: Case 27605

Dear. Mr. Jackson:

Enclosed please find two (2) copies of the revisions to Rochester Gas & Electric Corporation's Long Range Right-of-Way Management Plan and Annual Maintenance Program.

These revisions are the result of our correspondences and discussions dating back to 1992. Included are responses to your letter of recommendations dated February 10, 1993.

I trust these revisions satisfy you concerns and will bring a timely acceptance of programs by the Commission.

Please do not hesitate to call me should you have additional concerns.

Joseph F. Pasquini System Forester xc: M. Stoutenburg J. Williams

STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE INTEROFFICE MEMORANDUM February 15, 1995 TO: JOHN J. KELLIHER, Secretary, Central Files Case 27605 FROM: LAWRENCE W. JACKSON, Associate Aquatic and Terrestrial Ecologist, Office of Energy Efficiency and Environment

SUBJECT:

CASE 27605 - The Role of Herbicides in Managing Vegetation on Electric Transmission Rights-of-Way; Rochester Gas & Electric Corporation - Revisions to Systemwide Transmission Right-of-Way Management Plan RECOMMENDING: Approval of the revisions as requested On January 25, 1995, Rochester Gas & Electric Corporation (RG&E), in accordance with notification procedures set forth in item (j) of Appendix A of the Commission Opinion and Order 80-40 issued December 15, 1980, in case 27605, notified staff of several revisions to its approved systemwide Electric Transmission Right-of-Way Management Plan.

The revisions in their final form have been reviewed and commented on by staff. We find that this final version which includes organizational changes, provisions for implementing new technology, additional environmental protection measures and updated figures, tables and appendices fulfills all of the requirements of the Commission Order in Case 27605.

Staff recommends that the revised pages of RG&E's previously approved plan be approved and the company so notified.

(3)

Attachments cc: Joseph Pasquini (9W)w/o attachments L. Jackson OEEE Case File (K. Hammond)

APPROVED: .

\ J. KELLIHER k* A Secretary

ELECTRIC TRANSMISSION RIGHT-OF-WAY MANAGEMENT PLAN Rochester Gas and Electric Corporation Rochester, N Y.

January 1995

LONG-RANGE RIGHT-OF-WAY MANAGEMENT PLAN AND MAINTENANCE PROGRAM FOR THE ROCHESTER GAS AND ELECTRIC CORPORATION ELECTRIC TRANSMISSION SYSTEM Pursuant to 16NYCRR84.2 and 84.3 Under Public Service Law Sections 5(2), 65(1), 66(1) and 66(2)

Revised January 1995

TABLE OF CONTENT Page Section 84.2 Long-Range Right-of-Way Management 1 Plan for Electric Transmission System Introduction ........................................... 1 Electric System Description ........................... 2 Responsibility ......................................... 3 ROW Management History and Objectives ............... 4 Management Issues, Conditions and Procedures ........ 7 Management Techniques .................................. 8 Erosion and Sediment Control .......................... 15 Annual Maintenance Programs ........................... 16 Quality Assurance and Quality Control ............... 18 Notification Procedures ............................... 19 Research ............................................... 20 Permits and Licenses ................................ 20 Funding ................................................ 20 Plan Review ......................................... 21 Section 84.3 Transmission Right-of-Way Maintenance Programs and Schedule .................. 22 List of Tables ...................................... -ii List of Figures ...................................... -iii List of Exhibits ..................................... -iv List of Appendices .................................. -v-

-i-

LIST OF TABLES Number Title 1 RG&E ROW Management Techniques 2 RG&E 34.5 kV and 115 kV ROW Descriptions

- ii -

LIST OF FIGURES Number Title 1 ROW Management Plan Reporting Relationship 2 1993 NYPP Map 3 RG&E Electric Franchise Area Map ROW 1 - 12 RG&E Electric Franchise ROW System Maps

- iii -

LIST OF EXHIBITS Exhibit 1 Aerial Inspection Report Form Exhibit 2 ROW Maintenance and Vegetation Field Inspection Data Sheet and Inventory Report Exhibit 3 Electronic Site Specific Circuit Inventory RG&E ROW Treatment Maintenance Exhibit 4 Activities 1979 - 1993 Exhibit 5 RG&E Pesticide Notification Letter Exhibit 6 RG&E Pesticide Notification Log Exhibit 7 RG&E Pesticide Purchase and Use Form for Minor Applications

- iv -

LIST OF APPENDICES Number Title I Land Use Codes II RG&E Letter to NYPSC, May 30, 1980 III Selective ROW Management Specifications IV Key To Vegetation Name Abbreviation

Section 84.2 Long-Range Right-of-Way Management Plan INTRODUCTION This document describes the Rochester Gas and Electric Corporation (RG&E) policies and procedures for vegetation management on 115 kV and cross-country 34.5 kV electric transmission rights-of-ways. It includes a description of the Company's management structure and key personnel involved in long range planning, research, maintenance, funding, filing schedules and updating programs, as well as activities which may be undertaken to further this plan.

Terms used in this document include:

Transmission Rights-of-Way (ROW) - This refers to rights-of-way for all 115 kV and cross-country 34.5 kV transmission facilities and may include land owned in fee, strip easements, centerline easements, railroad and highway permits.

Right-of-Way Management Plan - This plan describes the programs, procedures and structures involved in ROW vegetation maintenance.

Right-of-Way Maintenance Procrram - This program is designed to incorporate the requirements of 16NYCRR84.3 and contains the specific standards, criteria, and maintenance schedules necessary to implement the ROW Management Plan.

Districts - The RG&E service territory is divided, for operating and maintenance purposes, into the Rochester, Canandaigua-Finger Lakes, Lakeshore and Genesee Pavilion districts. For purposes of the Right-of-Way Management Plan, each reports to the Division Manager, Energy Delivery ROW Inventory - The inventory reports results of surveys of each section of ROW to determine land use, acreage, vegetation density and species composition and identifies the best management practice for each area. The surveys are conducted by vehicle or on foot, depending upon the local terrain. A field review is conducted periodically.

Best Management Practices (BMP) - These are the treatment or combination of treatments recommended for a particular area, determined by the conditions of that area in order to implement the goals established in the constraints of the ROW Management Plan.

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Sensitive Areas - Line sections and lands adjacent to environmentally susceptible areas are noted on inventories and given special treatment considerations as special areas. Streams, wetlands, and unique habitat areas may require alternate treatments and attention to adequately protect the resource from possible adverse effects. Buffer zones have been established for sensitive areas to provide an adequate protection zone.

Capable Species - Any plant species which is capable of reaching heights at which it may interfere with electrical service integrity, or in the case of underground transmission lines, any woody plant, is considered capable of interfering with service integrity.

Environmental Management and Construction Plans (EM&CP)

These plans are designed to minimize environmental degradation during the construction of transmission lines requiring Article VII certification.

Desirable Species - These are species which either are not capable of threatening line security or will not, by their density, impede accessibility to the line for inspection or maintenance. Appendix IV lists a key to desirable, and undesirable vegetation by 34.5 kV and 115 kV lines.

Buffer Zone - Environmentally sensitive areas are identified and adequately protected through the use of buffer zones. Buffers are designated zones established around sensitive areas where mechanical and chemical control methods may be restricted.

Streams, wetlands, unique habitat areas, pastures, croplands, road crossings and residential areas may require special consideration including a buffer.

Electric System Description The RG&E franchise territory is located in two geographic provinces: the Lake Ontario Lakeplain and Appalachian Highlands.

While the topography varies from the Lakeplain in the North to the rolling, hilly Appalachians, the capable species are relatively constant throughout the franchise territory. The ROW system is largely surrounded by land in agricultural use, such as orchards in the north and dairy farms in the south.

The Company's transmission system, to which this plan applies, consists of 115 kV and cross-country 35.5 kV class lines which are predominantly on easement ROWs. The Company's franchise territory 2

is shown in Figure 2. Detailed maps of both the 115 kV and 34.5 kV ROWs described in Tables 2 and 3 are found in Figures ROW-i through ROW-12.

Development and implementation of the Rochester Gas and Electric Corporation Right-of-Way Management Plan are the overall responsibility of the Division Manager, Energy Delivery (see Figure 1). Initial preparation and maintenance of the Plan are the responsibility of the RG&E ROW Management Committee. The various representatives on this Committee and their functions are discussed on page 14. Implementation of the plan is the direct responsibility of the System Forester whose duties are also described on page 3. Quality assurance for implementation of the plan is provided by the Environmental Sciences Department. The plan is periodically reviewed by the ROW Management Committee. The results of the reviews and recommendations regarding the program are then reported to the Manager, Engineering Services for information and/or approval.

The ROW Management Plan was implemented initially on a three-year cycle. During this first cycle the condition of this relatively small ROW system was reviewed. Problems identified with the plan implementation during this period have been corrected. As anticipated, upon review of the first three-year cycle, the plan has been expanded to an average of five years for non mechanical treatment areas.

RESPONSIBILITY The Division Manager, Energy Delivery, through the System Forester, has overall responsibility for the ROW Management Plan and must approve all annual and long-range budgets and revisions to the plan.

The System Forester, through the District Managers, and ROW Management Committee, has the responsibility for developing and recommending annual and long range budgets and ROW Management Plan changes. The System Forester reports to the Standards and Technical Services Group, and is responsible for coordinating and implementing the Row Management Plan, co-developing budgets with the appropriate District representatives, inspecting maintenance 3

crews, implementing EM&CPs, developing ROW contractor bid specifications, coordinating multiple-use activities, title transfers or limited use agreements for Company rights-of-ways, and keeping the ROW inventory current. The System Forester will have, or will have at his disposal, persons who have knowledge of vegetation sufficient to conduct inventories and determine best management practices as necessitated by appropriate electrical and environmental standards.

The Right-of-Way Management Committee, which is composed of representatives of several different Departments within RG&E, is responsible for the preparation and maintenance of the ROW Management Plan. This Committee meets yearly to review the implementation of the Plan and to recommend any changes that are found to be necessary.

The Manager of Environmental Sciences will provide quality assurance regarding implementation of the program and will be the Company Agent for filing any regulatory reports and satisfying appropriate permit practices.

ROW MANAGEMENT HISTORY AND OBJECTIVES Prior to 1978, nearly all ROW maintenance activities at RG&E were conducted by mechanical hand cutting or hydro-ax. Except for limited instances, herbicides were not utilized as a normal maintenance tool.

Starting in 1978, the Rochester District and two of the rural Districts initiated ROW maintenance activities using herbicides in a selective manner on their 34.5 kV ROWs. During that same year, a ROW Management Committee was formed to develop a standard ROW Management Plan that could be instituted for the Company's entire transmission system. An inventory of the 115kV ROW network was conducted and Best Management Practices (BMP'S) were developed and assigned. In 1978, a maintenance program was begun to treat the priority areas during the first year of a proposed three-year cycle, with the remaining ROW acreage to be divided in half and treated over the remaining two years.

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RG&E initially chose the three-year cycle in order to quickly treat all sections of the right-of-way. Those areas that contained the highest densities and heights of capable species were given the highest priorities in the initial cycle. Areas exhibiting lighter densities and smaller heights of capable species were treated in the latter two years of the cycle. Present maintenance work is conducted on an average five-year cycle. The initial three-year cycle, in conjunction with succeeding treatments, have significantly reduced the density and height of capable species.

The length of this maintenance cycle depends on many factors, such as voltage class, height of poles, land use and vegetation composition and growth rate. On some of the 115 kV circuits ROWs this maintenance interval may be expanded even further, while on some of the 34.5 kV ROWs, it may be reduced.

The "primary objective" of the ROW Management Plan is to maintain the electrical integrity of the transmission system at a minimum financial and environmental cost to RG&E's customers.

Second only to maintaining electrical integrity, the ROW Management Program is designed to improve the efficiency of the maintenance operation. RG&E feels this is currently best conducted by coordination of a uniform maintenance program under the auspices of the System Forester, and by the selective use of herbicides, which will extend the length of the maintenance cycle, and improve efficiency, economics and environmental benefits. In recognition of the continually changing economic, environmental and social factors which must be reflected in implementing this Plan, it has been designed around the following additional "secondary objectives:"

(1) selective clearing and treatment should encourage the establishment of low-growing, relatively maintenance-free ground cover; (2) these low-growing plant associations should reduce maintenance costs when the costs are pro-rated over the life of the right-of-way; (3) neither electrical security nor line maintenance access are to be significantly impeded under this Plan; (4) biological diversity should be enhanced by the variety of low-growing vegetation types promoted by the Plan.

Diversity provides a wider variety of habitat for wildlife; 5

(5) visual softening of ROWs should be strengthened by fostering a grass, forb, shrub, and/or small tree community within the selective vegetation concept; (6) recreational benefits, in both consumptive and non consumptive forms, are to increase (activities such as berry picking, horseback riding, snowmobile riding, hiking and bird watching are suitable forms of activities on fee-owned ROWs.)

Organized activities usually require a permit from the Real Estate Office of the RG&E Engineering Department.

In line with the primary objective of the maintenance program RG&E intent is to quickly bring the entire system into a manageable, fairly uniform vegetative condition. To accomplish this objective, three methods were employed: hand cut stump treatment (Method HC,ST), selective foliar (Method FS), and hydro axing (Method HA). See pages 8 and 13, Chemical Methods, Mechanical Methods for definitions.

These "secondary objectives" will be measured in several ways.

When the original inventory was conducted, information regarding the type of land use, capable species densities, sensitive areas and other pertinent notes were taken. From this initial base line data, brush acres and methods to be employed could be computed on the percent of desirable ground cover and variety of desirable species. Recreation use was only noted in a casual fashion or ocularly noted. It was felt that the data compiled regarding the capable species was the most important data to obtain since these were the species that are the live security risks. It is also known that nature abhors a vacuum and that with the lowering of the densities of capable species, vegetation invasion, predominantly of desirable plants, would take place. This will be measured by the updating of the inventory data base. Where first RG&E may have recorded heavy density and high height, an update (using the same land use codes) may find medium or low density and low height. It would be clear then that the desirable plants have invaded the niche formerly occupied by some of the capable species. It can further be implied through this reduction of capable species and densities, that maintenance activities would be lessened, and the potential for recreational activities would increase due to the large variety of plants and animals now found on the ROW system.

This increase in the diversity of habitat would also "soften" the view shed that ROW's sometime exhibit.

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Primary and secondary objectives are reviewed during three general periods: inventory, work, and follow-up; over a three year period.

MANAGEMENT ISSUES, CONDITIONS AND PROCEDURES Regulations, current and proposed land use on the ROWs, environmentally sensitive areas and management techniques are all considered and weighed before a BMP is selected in the light of the objectives listed above. These BMPs are determined on a case-by case basis, tailored specifically to the condition of the area under review.

The RG&E selective clearing philosophy, utilizing herbicide treatments, entails treating only those species that are a risk to the integrity of the transmission line. All other species are left untreated to reduce the potential for reoccurrence of capable species. To determine the proper BMPs to employ for a specific area, factors such as species, density, height, environmental sensitivity, current land use and any special or landowner concerns; are evaluated.

The economies of maintaining the ROW system are, of course, carefully noted and documented. By employing the best management practice (BMP's) for a specific situation in a specific time frame, carefully reviewing the results and keeping abreast of all of the latest research activities, maintenance costs should decline from the initial program to a relatively stable budget.

The establishment and maintenance of the ROW vegetation inventory is central to the ROW Management Plan and forms the nucleus of the maintenance cycle. The System Forester's own vegetation surveys and maintenance activities will be used to maintain the vegetation inventory. Considered with the inventory are the results of aerial patrols and data which pinpoint areas where electrical outages are possible. The aerial patrols are flown two times a year. All of this information will be evaluated and used to achieve the goal of low-growing, compatible vegetation on the ROWs.

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MANAGEMENT TECHNIQUES The current control methods available for ROW clearing and maintenance work are either mechanical, chemical, or a combination of the two. These techniques provide the System Forester with a "tool box" from which he can choose the BMP(s) for a specific area.

As new techniques, social pressures, and/or regulatory developments occur, the System Forester can adjust his program accordingly.

Chemical Methods

  • Since 1978 vegetation management on most transmission power lines has been accomplished through the selective use of chemicals in non-sensitive areas. Many herbicide formulations are now available and a variety of techniques for their application have been developed. While most herbicides are applied by spraying, other methods such as injection and frilling may sometimes be used.

The development of low volume, low volatile herbicides, and the various particulating agents and thickeners has done much to make herbicide spraying more acceptable. Off-target damage due to volatilization and drift can now be avoided.

There are two general kinds of spray applications: (1) broadcast or blanket spraying, where all plant species in an area are indiscriminately covered; and (2) selective spraying where only undesirable species of plants are sprayed and desirable vegetation is left. Presently, all rights-of-way spraying is selective and applied from the ground.

A major objection to rights-of-way spraying is the visual impact of dead foliage, called "brownout." "Brownout" occurs whenever foliage is present at the time of spraying. "Brownout" occurs with most foliar sprays and can be undesirable in highly visible areas. It can be avoided by spraying during the dormant season using basal or dormant-cane techniques as described below.

  • From Jack B. Cody, "Vegetation Management on Electric Transmission Lines - A State of the Knowledge Report", a special report to the Empire State Electric Energy Research Corporation, State University of New York College of Environmental Sciences and Forestry, Applied Forestry Research Institute, Syracuse, New York, AFRI Research Report No. 28, November 1975, pp. 9-13 8

Chemical Application Techniques Hand cut, stump treat (HC,ST) is incorporated in areas where capable species are either greater than 8-10 feet high, in sensitive areas or of such size and density that a hydro-ax could not be used for clearing.

Selective foliar (FS) is used extensively in areas of medium density and medium height of capable species. The method is more suited than the hand cut, stump treatment.

Selective foliar is also used in areas where desirable species are more prevalent, or as a follow-up to hydro-ax and also for picking up any misses from HC,ST.

Basal Bark (BS) is used on established right-of-ways where the conversion to a predominantly desirable vegetation type has been accomplished.

The combining of these methods will place the RG&E ROW system in a position where capable species densities and heights will be less than the original conditions. Succeeding cycle are currently employing Methods HC,ST (hand cut stump treatment), FS (foliar) and (BS) basal bark . These three methods will provide the selectivity and economy needed to maintain the increasingly higher density of desirable species while further reducing capable species densities.

The methods listed below can all be utilized for ROW treatment. A matrix has been developed to indicate the various criteria considered in choosing one method over another (see Table 1). RG&E chose the methods listed in Table 1 because they have been determined to be the most appropriate, based on empirical data, for Company maintenance activities. This matrix provides a quick reference for comparing the various methods employed by RG&E.

Ground Applications Ground application of herbicides require the application of liquid materials utilizing application techniques which employ various pieces of hydraulic equipment including large motorized track and rubber tired vehicles to small man carried backpack and squirt bottle containers, utilizing hand-controlled nozzles.

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Evaluating a site for ground application requires consideration of target vegetation, terrain, site accessibility and stem density. Application technique, nozzle type, spray wands and herbicide rates or mixes can be varied according to the needs of the site.

Applications should be made only when there is little or no hazard from spray drift. To aid in reducing spray drift potential when making ground applications near susceptible crops of other desirable plants, herbicide should be applied through large droplet producing equipment and thickened with drift control agent.

Additional surfactant and adjuvant may be utilized to improve the wetting, spreading, and penetrating characteristics of the herbicide product.

Ground applications are the most selective in treatment specificity.

The following chemical control techniques are used by RG&E.

Low Volume Foliar Application (FS*) - Low volume applications reduces spray volume from hundreds of gallons of mix per acre to only 10 to 20. Actual concentrate is applied at the rate of 1 - 4 quarts per acre. Either backpack or hydraulic equipment may be used. Spray pressure is reduced and should not exceed 50 psi at the pump and 30 psi at the nozzle except when moving solution long distance or up hillsides. Reduced pressure will minimize over spray and drift.

Low volume treatments require wetting but not soaking of leaves.

Undesirable brush up to 10' in height may be successfully controlled using a spray mix containing a 1 - 5 % herbicide product (by volume). Backpack units should be capable of maintaining 30 psi. Recommended backpack sprayers include Solo, Birchmeier or Hudson type sprayers.

Foliar Application (FS**) - In foliar applications the concentrate spray material is mixed in enough water (100 - 200 gallons/acre) and applied to the leaf surface at the rate of 1 to 8 quarts per acre. While it is not necessary to completely wet the leaf surface, uniform coverage is important and some chemical should be deposited on each leaf. No attempt should be made to wet 10

the stem, but some stem wetting will occur. Spray volume is usually low since only the leaf surfaces are wetted, and then not completely. Pressure should not exceed 200 psi at the pump and 60 100 psi at the nozzle. Foliar spraying is accomplished utilizing ground equipment and a hand held nozzle. Best results are achieved on light to medium density brush from early summer through early fall.

HiQh Volume Stem Foliar Applications (FS***) - Stem-foliar spraying, as the name implies, means that both the stems, foliage, and root collars are wetted with the spray materials, or in this case to the saturation point. It may be used selectively where the vegetation is sparse, but its main use is in selected areas of dense undesirable vegetation where coverage of the majority of woody plants is desired. It may also be used where all woody species are undesirable or in access roads where all woody plants need to be removed. In general, the same herbicides are used as in foliar spraying, but the spray volume is usually about double; 8 - 12 quarts per acre, 100 to 400 gallons of total spray per acre.

Better translocation occurs than with the lower volume foliar sprays in heavy undesirable stands due to the stem wetting and rundown; providing better root kill. Timing of the spray application is not so important as with foliage spraying, and good results can be obtained from first full leaf development until late summer. Late summer applications give improved root kill with certain herbicides and are recommended for root suckering species.

Basal Bark and Dormant Brush Treatments (BS) - For basal bark treatments, herbicides are mixed with an oil carrier. Oil carriers acceptable are those commercially available such as CWC HY-GRADE II or Arborchem Basal Oil, or diesel fuel.

Basal treatments may be applied either with a knapsack sprayer or power spraying equipment using low pressure (20-40 psi).

For traditional basal treatments the bottom 12 to 15 inches of stem and the root collar are thoroughly saturated using a 1% - 5%

product mix. For low volume basal bark treatments a 20% - 30%

product mix is utilized to spray the lower 15 to 20 inches of the stem in a manner which thoroughly wets the stem, including the root collar area, but not to the point of runoff. Basal applications are used to control stems less than 6 inches in basal diameter.

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Basal sprays are more easily confined to the target species than any other spray methods and are generally used where a high degrees of selectivity is desired.

The cost of basal spraying compares favorably with other methods at low brush density, but rises sharply with increased density.

Basal spraying can be accomplished at any time of the year as long as there is free access to ground line. It is primarily used during the dormant season to prevent brownout. It is also used as a pre-clearing treatment to prevent stump sprouting. As a pre-treatment it helps avoid misses caused by stumps being obscured by cutting debris.

Cut Stump Treatment (HC,ST) - Undesirable trees are cut at grade (stumps to be 3" or less) with a chain saw and stumps are treated with a herbicide. Stump treatment is used primarily during initial rights-of-way clearing and on highly visible right-of-way sections where standing dead brush is not desirable. After cutting, stumps are treated by thoroughly wetting the outer edge of the cut surface. For best results the stumps should be treated as soon after cutting as possible with a herbicide.

With proper treatment, this method can be highly effective.

However, since kill is usually only to ground line, stump treatment may give poor results against root suckering species on newly cleared rights-of-way.

One full growing season following initial clearing operations, utilizing a cut stump treatment, a selective foliage treatment may be applied to sprouting or suckering undesirable brush.

Cut-Surface-Methods - Cut surface methods include applying herbicides with tree injectors and injection hatchets (Hypo Hatchet); or in frills, spaced cuts, cups and notches made with an ordinary axe or hatchet. While used extensively in forestry, cut surface methods have found only limited use in rights-of-way. Cut surface methods should probably be more used as a pre-clearing treatment (especially on root suckering species), on roadside 12

screens, on selectively cleared rights-of-way, f or danger tree elimination, and for elimination of root suckering species with roots extending into the right-of-way. The use of a herbicide containing picloram will help prevent stem sprouting and root suckering (Cody 1973).

Mechanical Methods The effects of mechanical treatment are temporary. When many woody plants are cut or mowed, sprouting (via stump or roots) occurs, with a resulting increase in density and a shortening of the maintenance cycle.

Mechanical methods are most suited to special consideration areas such as chemical exclusion areas and seasonally dry wetlands.

Hand Cutting (HC)- This method employs a chain saw and should be used on capable trees greater than 10 inches in diameter and in areas where access is limited. It is selective, but is slower and more expensive than motorized mechanical devices. Residential areas, buffer zones, wetlands, highway screens and spot treating are areas where hand cutting is usually recommended: side trimming, described below, is a hand cutting technique used largely in residential areas.

Mechanical Clearing Machine (HA) - This term usually refers to a machine known as the Hydro-ax or Kershaw mower. This machine can cut trees up to 10 inches in diameter at the rate of several acres a day, depending on stem density and terrain. It is essentially nonselective and a good device for clearing ROWs that are composed of young undesirable species in a relatively pure stand. The current practice is to use a foliar application on the suckering stumps one full growing season after Hydro-axing.

Mowing - This technique is primarily used in areas where selective chemical treatments are not recommended as best management practices. Terrain must be flat with no gullies or rocks. Several suburban and urban ROW segments are mowed with a brush hog or finishing mower, where grooming is important. While the appearance of the ROW is pleasing mowing may be required several times a year.

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Side Trimming (SIT) - This refers to pruning vegetation with a chain saw that is overhanging or leaning into the ROW but not actually growing on the ROW. This technique is used in rural off road areas. Selective Trim (SET) is used to cut or top landscape trees where removal is not possible.

Danger Tree Removal - This refers to the removal of large trees outside the maintained or established right-of-way area.

Danger trees are those trees which are capable of causing a system disturbance due to the size, condition, and proximity to the conductor. Danger trees are identified through yearly line inspections and inventories, marked and removed by chain saw following customer notification.

Disposal Techniques Slash Disposal - After the vegetation is cut, depending on density and access requirements, it usually must be moved or disposed of in some fashion. While all the methods for slash disposal listed below are viable, RG&E currently uses lop and drop, and windowing as the most common methods. This selection is based on and tempered to the particular maintenance requirements of the Company.

Specifications for each disposal type are listed in Appendix III section 2.2.

Chipping (CH) - Woody material is chipped and piled, spread in a layer, or hauled off-site. Chipping is prescribed as a disposal technique when the accumulation of wood and brush may not be desirable on the right-of-way following hand cutting treatment.

Locations such as wetlands, road crossings, stream crossings and residential areas may be prescribed as chip sites. Chipping is often recommended on sites adjacent to residential areas due to fire concerns.

Chipping can prevent erosion along certain areas, although too thick a layer of chips will be detrimental to the establishment of the desired low-growing ground cover. Chips should be evenly applied to the right-of-way to a thickness of 2" to 3" unless they are to be used for off-site mulch.

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Lop and Drop (LD) - Woody material is cut into pieces and left to lie where it drops. While good for erosion control and inexpensive, this method can create an accessibility problem for security checks and maintenance or preclude the spread of desirable plants.

Lop and drop is prescribed as a disposal technique on hand cut sites with light to moderate undesirable stem densities for stems over 3". It is also used in wetlands where machine access is difficult and would result in site impacts.

Lop, Drop and Scatter (LDS) - Same as above except material is moved sufficiently so that accessibility is less of a problem.

Hand Pile (HP) or Mechanically Pile and Crush (PC) - Woody material is piled by hand or machine piled and then crushed by a bulldozer. This method provides wildlife habitat and erosion control but may be aesthetically offensive if piles are not properly located.

Hand piling is used on sites where mechanical equipment may not be utilized due to access, terrain, or environmental concerns.

WindowinQ (WR) - Woody material that has been de-limbed is carried by hand or pushed with a bulldozer to either side of the cleared right-of-way. Windowing makes access easier but it can increase erosion and be difficult to use in selectively cut areas.

EROSION, SEDIMENT CONTROL, AND STREAM CROSSINGS Erosion and sediment control practices/measures are designed and employed to protect the natural character of rivers, streams, lakes, wetlands, or other water bodies and soils from the deleterious affects of erosion and sedimentation. Measures are taken to minimize erosion and sedimentation from the start of land disturbances during construction through establishment of permanent stabilization.

Through proper planning, both temporary and permanent structural and vegetative erosion and sediment control measures are designed and utilized to control runoff, stabilize soils, and control sediments.

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Critical to erosion and sediment control measures is the calculation of land area disturbed (acres), soil erodibility, land slope, rainfall, and disturbance duration. Based on this information various vegetative, bio-technical, and structural control measures (both temporary and permanent) are recommended.

Maintenance of both vegetative and structural erosion and sediment control measures and devices is vital to their effectiveness. Following installation each application is annually inspected to insure structural integrity and identify maintenance requirements. Repair and maintenance is prescribed based on the annual review.

Stream protection practices are employed to preserve and safeguard the integrity of the valuable water resources of New York States rivers, streams, lakes and ponds.

Construction and maintenance practices are engineered to be compatible with the preservation, protection, and enhancement of the present and potential values of the water resources found on the rights-of-ways.

Culverts, bridges and fords are constructed and maintained to prevent the disturbance of the bed or banks of all protected streams mapped as "C(t)" or higher and other lower class streams.

Permits are obtained for regulated activities that occur in or near protected waters.

ANNUAL MAINTENANCE PROGRAMS Preparation of annual maintenance programs and schedules for individual ROWs begins with an inventory of the transmission ROW system. The inventory (see Exhibit 2) includes several resource items: (1) current land uses, (2) desirable and undesirable species, (3) percent of undesirable species, (4) density and height of capable species, (5) special areas of concern (ie: streams, wetlands, wells, easement restrictions, and access agreements), (6) total acreage, (7) total brush acres and (8) the preliminary BMPs (if any) needed to bring a particular section within the management goals (see exhibit 2), and (9) comments, which are used to identify unique site considerations or attributes.

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The land use codes that are utilized for the inventory are described in Appendix I. The results of the analysis are then.used to determine ROW area priorities, final BMPs and projected treatment costs.

RG&E began its program in 1978 with a three-year cycle to bring all the ROWs into compliance with Company standards.

Emphasis was placed on the speed and cost of the program. Upon completion of the last year of the first cycle, a complete updating of the original inventory was initiated. In 1983 a maintenance cycle of five years has begun due to the lighter density and shorter height of the remaining capable species. The data from the end of the last cycle helps determine the number of years in the next cycle. The "five" year program has become the typical maintenance cycle, the length of which will depend upon funding, weather, growth conditions, etc. While the cycle may appear to be fixed, it is flexible due to the ground and aerial patrols which can spot problem areas that may be growing faster than other areas, requiring spot treatments prior to scheduled treatments. Spot treatments occur as required based on patrol results as prescribed on page 22. Typically spot treatments usually address chemical exclusion sites such as road crossings, streams and wetlands and encroachments.

RG&E generally does not provide vehicle access along its transmission rights-of-ways and subsequently access road maintenance is not required. Inspections and patrols are performed by helicopter, walking, and driving using off road equipment.

The cumulative effect of the program will be to: (1) reduce overall costs, (2) reduce the density of capable species, and (3) reduce total acres of brush that need to be treated yearly.

The 115 kV system has been totally inventoried as of 1980 and re-inventoried with succeeding treatments. A re-inventory of the cross-country 34.5 kV ROWs has been completed and is updated on an as needed basis.

The overhead electric transmission system for all 115 kV and 34.5 kV lines consist of approximately 710 pole miles.

Approximately 500 pole miles consisting of 2400 line acres are part of the maintenance plan.

17

The 115 kV ROW inventory consists of approximately 213 pole miles or 700 line acres of brush requiring treatment. The 34.5 kV ROW system inventory consists of approximately 287 pole miles or 900 line acres of brush requiring treatment.

Nothing unique about the RG&E ROW system necessitates implementing or developing special methods over and above those currently employed.

The most common capable species found on the RG&E system are ash, maple and aspen; the desirable species are the dogwoods (grey stem, red, silky) and the viburnums (see appendix IV). In certain cases, the dogwoods and sumac may also be included in the capable species class, especially where their density precludes reasonable accessibility to the lines, such as on 34.5 kV ROWs. Currently, all ROW maintenance work is done by contractor forces. As described in an RG&E letter of May 30, 1980, to the Public Service Commission (see Appendix II), the Company conducts a comprehensive pre-bid meeting with the invited contractors, thoroughly explaining the Company's selective clearing specifications. The Company also conducts a site inspection of the areas detailed for maintenance.

The selected contractor's work forces are briefed regarding the specifications, and the desirable and undesirable vegetation is identified. A copy of the RG&E selective clearing specifications are included as Appendix III.

QUALITY CONTROL, QUALITY ASSURANCE During the course of the maintenance activities the contractor's work is field reviewed regularly by the System Forester or his designated agent. This frequent field verification during the contract period ensures compliance with the all contract obligations including: primary and secondary objectives, selective clearing specifications, and Federal and State Laws. Inspections identify problems early in each job and makes for smoother working relationships between contractors and RG&E. When each particular project is concluded, the System Forester will verify that the work has been completed according to specifications and authorize the final payment. However, if the 99% guaranteed kill criterion in the clearing specifications has not been achieved by the following growing season, the contractor is then obligated to treat the ROW again in order to fulfill the requirement.

18

Since all maintenance work is done by contractors, cost accounting is greatly simplified. Bids are submitted for each project on a lump sum basis plus an estimate of the cost of any extra work that may be required on a cost/acre/method basis.

Payment for any extra work deemed appropriate for that particular project is then made to the contractor, according to the unit price schedule that is submitted with his bid. Administrative costs are charged separately, as are the different ROW projects for each district. Under this procedure, detailed cost accounting forms are not necessary.

NOTIFICATION PROCEDURES The System Forester, with the assistance of the Contractor, attempts to personally notify property owners in advance of the maintenance activities. Notification includes pertinent label information as required by the New York State Department of Environmental Conservation, ECL Article 33, Titles 9 and 10. The method of notification to be employed will consist of one or all of the following:

1. personnel contact
2. door knob hanger or
3. mailing In addition, areas to be treated may be posted at conspicuous locations, such as crossroads, prior to treatments.

Notification procedures are more fully detailed in Appendix III.

Owners of land adjacent to fee-owned ROW's are generally not contacted since the method(s) employed by the company are carefully chosen to minimize visible off-ROW concerns. Problems or concerns raised by off-ROW owners are dealt with on a case-by-case basis.

Every effort is made to inform the concerned landowner regarding the maintenance methods and herbicides (if any) to be used on or adjacent to their land. If the concern(s) can not be resolved, RG&E will only conduct maintenance activities that provide short term relief, but which increase the frequency of the maintenance activities in that area. These cases are extremely uncommon at RG&E.

19

RESEARCH RG&E is a member of the Electric Power Research Institute and the Empire State Electric Energy Research Corporation, and benefits by their research in this field. Information concerning RG&E's research plans and structure is detailed in the annual Report of Member Electric Systems of the New York Power Pool and the Empire State Electric Energy Research Corporation Pursuant to Section 5-112 of the Energy Law of New York State, Chapter 10.

No additional research is conducted by RG&E.

PERMITS AND LICENSES The Manager of Environmental Sciences is responsible for obtaining all permits and licenses required to carry out the various aspects of the ROW Management Plan. Since all ROW maintenance work is contracted, RG&E only needs pesticide certification for a few employees assigned to manage maintenance work. The contractor has responsibility for proper application of herbicides, disposal of herbicide containers and renewal of certification of its own pesticide applicators and equipment applicators, and maintenance of records. Currently, the RG&E ROW Maintenance Program does not include any other activities which require environmental permits or licenses.

FUNDING Development and approval of the annual and long-range budget forecast involves these major steps:

(1) The System Forester develops projected costs based on inventory records. Projected costs for each year are based on average historical contractor prices for specific BMPs. These costs are multiplied by the total brush acres prescribed for each method. Administrative costs and inflation are also included.

20

(2) The System Forester and the appropriate district representative modify the forecasts as necessary to meet the specific yearly needs.

(3) The Division Manager, Energy Delivery in conjunction with the Manager, Engineering Services and the Standards and Technical Services Group approve budgets.

The ROW Management Program budget remains relatively flat. As the program continues to mature, real costs will decrease. As ROW vegetation stabilizes, conformance with program goals is expected.

Costs, except for the influence of inflation, should remain relatively constant.

PLAN REVIEW The ROW Management Committee is responsible for the preparation and annual updating of the ROW Management Plan. The committee meets yearly for this review process.

The criteria considered to determine the effectiveness of the annual maintenance activities in relation to the plan's objectives would include, but not be limited to:

1. Number, type and location of outages
2. Costs, primarily on a cost per acre basis
3. Increase in density of desirable or capable species (ocular estimate)
4. Customers concerns and challenges (calls,restrictions,complaints, etc.)
5. Variety of desirable vegetative types found
6. Effectiveness of herbicide kill
7. Regulatory input (regulations)
8. Multiple use activity Recommended program changes will be sent to the Division Manager, Energy Delivery and the Manager, Engineering Services for review and approval. Should conflicts arise, the Division Manager has the responsibility to resolve the matter.

21

Sections 84.2 and 84.3 are control documents that will be revised upon approval by the ROW Management Committee. The PSC will be provided with change pages as they occur.

The members of the Committee represent all the areas of ROW involvement at RG&E, including:

Environmental Sciences - charged with regulatory contacts, permit/licensing applications and EM&CP program development System Design Engineering - charged with engineering of new overhead and underground transmission facilities and modification of existing ones Property Assets - charged with obtaining necessary easements or purchasing property for transmission facilities as well as maintaining landowner records Districts - the four districts (Rochester, Canandaigua-Finger Lakes, Lakeshore and Genesee Pavilion) are charged with maintaining line security for their respective areas System Forester - charged with coordinating and implementing the ROW Management Program, co-developing budgets with the appropriate Managers and inspecting maintenance crews, implementing EM&CPs, developing ROW contractor bid specifications, coordinating multiple-use activities, title transfers or limited use agreements for Company rights-of-way and keeping the ROW inventory current.

Section 84.3 Transmission Right-of-Way Maintenance Proqrams and Schedule Inspection of the RG&E electric transmission ROW's has been an ongoing practice for over thirty years. Both ground and aerial surveys are employed in this inspection process.

Aerial patrols are conducted routinely two times a year and the ground patrols generally once a year.

22

The purpose of these patrols is to inspect for: (a) mechanical and/or electrical damage, including thermal breakdown, and (b) tree conditions (height and densities) which could affect the integrity of the lines or accessibility for maintenance. If neither mechanical nor tree problems are found, it is noted on the survey sheet, which is maintained by the System Forester for a minimum of five years.

The specific periods within which remedial action must be taken when field problems are encountered by patrols are:

Priority One - Leaves/branches burning in conductors action initiated immediately, within 24-48 hours.

Priority Two - Close tree branches (2-3 feet from conductors) - action taken within 30 days.

Priority Three - Tall capable species (15-20 feet high) action taken within a 120-day inspection period.

In instances where vegetation outside our right-of-way interferes with the safe operation of the line (i.e. danger trees),

the property owners are contacted in an attempt to secure the necessary rights to remove or trim that vegetation. These instances are handled on an individual basis.

The System Forester, and the Districts use their judgment in determining when this is necessary.

RG&E prepares an annual schedule for the treatment of vegetation based on the results of the ROW inspections. It is on file with the Environmental Sciences Dept. and submitted to the Public Service Commission, Department of Health, and the Department of Environmental Conservation, on an annual basis.

Copies of RG&E's standardized inspection reports are attached as Exhibits 1 and 2. Exhibit 1 is for aerial inspections and Exhibit 2 is a combination ground inspection and ROW maintenance survey sheet. Data from both types of surveys are used to schedule annual treatment programs as well as to develop inventories.

23

The form used for ROW maintenance and vegetation treatment is attached as Exhibit 2. This form includes the type (method),

location, acreage and date of all mechanical, chemical or other treatments to be employed on an annual basis.

Herbicide usage records will be kept on the standard DEC Certified Commercial Applicator Record of Pesticide Purchase and Use (Form 44-14-15) for spot applications, and on Contract Specification and Inventory Report Forms for bid work. Records will be retained for three years. In addition, inspection and maintenance reports will be maintained as a permanent file for the duration of the maintenance cycle. As previously noted, these forms contain ROW inspection dates maintenance schedules and maintenance activities for each ROW that is included under this program.

The maintenance information will be summarized on an annual basis and retained as a permanent record for each electric transmission facility.

24

TABLE 1 BASIC RG&E ROW MANAGEMENT TECHNIQUES EFFECTIVENESS CONDITIONS (FREQUENCY APPROXIMATE MECHANICAL METHODS USED OF USE)* COSTS16 YR. CYCLE COMMENTS METHODS*** < 10" diameter 2-4 Years Quick, inexpensive, Any height essentially non medium-heavy 4 selective method; Hydro-ax density of shattered stumps may relatively pure $445./A cause accessibility stands of difficulties. No capable species residual control.

Ž 8' height 2-4 Years Slow for heavy Hand Cut Any size 5 densities; No Herbicide light-medium very selective. No density, sensitive $766./A control.

areas, evergreens Urban-suburban Yearly to Several Limited by terrain, (No Method Letter) areas, grass Times a Year 5 frequency is high; areas, sensitive limits species

& herbicide $625./A diversity exempt sites CHEMICAL METHODS Same as Method A 5-6 Years Possible except herbicide 3 translocation of is applied to herbicide on root Hand Cut stump $423./A suckering species With Herbicide to off-ROW species, very selective

< 8" height 5-6 Years Volatility; Selective Any density 2-3 possible drift Foliar of herbicide;

$340./A seasonal applications only. Excellent control.

Medium to light 5-6 Years Very selective but Basal density 1 prohibitive cost where 8' height vegetation density is

$310./A high; leaves standing dead trees.

  • -Varies with voltage class and vegetative growth.
    • -Rated 1-5, with 5 the most expensive, this will vary with density
      • -Refers to the code letter assigned to each method in the RG&E Selective ROW Management Clearing Specifications.

M rowmln jp

Table 2 Page 1 of 9

  • Pc:Lotus:RowDescription ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS ANDSCHEDULE OF TREATMENTS CIRCUIT DATE OF LAST FROM TO VOLTAGE TYPE OF APPROXIMATE TYPE OF WIDTH NLUMER OF IN KV CONSTRUCTION LENGTH OF RON OF ROW CIRCUITS ON NUMBER NEXT TREATMENT ROW LINE IN MI.

34.5 kV Rights-of-Way Stone Rd., Town 34.5 Single circuit, steel 1.5 Centertine 1 - 34.5kV 701 '-u' 1994 S ta. 56, Pittsford of Pittsford towers & single wood poles easement ThornetL Rd., Pitts 34.5 Single circuit steel 1.4 Centertine 1 - 34.4kV 701 ( 1994 Kinickerbocker Rd., Pitts.

towers & single wood poles easement Railroad Mitts Rd., Pitts 34.5 Single circuit, single pole 1.3 Fee owned 1001 1 - 34.5 kV 701 & I 1994 TIhornetL Rd., Pittsford Sta. 154, Victor 34.5 Single circuit, steel 6.5 Centertine ----.. 1-34.5kV 701 01 1995 R*aitroad Mitts Rd., Pitts.

towers & single wood potes easement Victor Sta., 115, Mendon 34.5 Single circuit, single pole 2.1 Centerline . -- 1.- 34.5kV 701 1995 Wangun Rd.,

easement Ecldy Rd, Wittaimson 34.5 Single pole, and 3.9 Easement and 400' 5 - 115 kV 702 1989 s ta. 204, Ontario Single pole, underbuilt on 908 Centerline 2 - 34.5 kV Sta. 193, Marion 34.5 Single circuit, single pole 1.3 Centertine -----. 1-34.5kV 702 1989 Dean Rd., Marion easement North of Atlantic Ave., 34.5 Single circuit, single pole 3.1 Easement 400' 5 - 115 kV 702 1991 C revenger Rd., Ontario Walworth 1 - 34.5 kV Sta. 124, Penfield 34.5 Single circuit, single pole 4.1 Fee owned 400' 2 - 115 kV 702 1990 North of Atlantic Ave., 1 - 34.5 kV Watworth Sta. 202, WitLaimson 34.5 Double circuit, single pole 6.0 Fee owned 100' 1 - 34.5 kV 703 1989 s ta. 204, Ontario 1 - 115 kV Sta. 156, Manchester 34.5 Single circuit, single pole 1.3 Centerline -----. 1-34.5kV 704 1991 Sta. 168, Manchester easement Ontario County Rt. #19 34.5 Single circuit, single pole 1.3 Centertine 1 - 34.5kV 704 1991 s ta. 156, Manchester easement Sta. 7105 34.5 Single circuit, single pole 1.3 Centerline 1-34.5kV 704 1991 0ntario County Rt. #19 easement Sta. 153, Canandaigua 34.5 Single circuit, single pole 1.6 Centertine S1-34.5 kV 704 1991 S ta. 155, Canandaigua easement Sta. 189, Red Creek 34.5 Single circuit, single pole 6.1 Centerline 134.5kV 708 1995 Sta. 192, Wolcott easement Sta. 198, North Victory 34.5 Single circuit, single pole 4.6 Centerline 1-34.5 kV 708 1995 Sta. 189, Red Creek easement 1995 S'wamp Rd., Victory Yates Rd., Butter 34.5 Single circuit, single pole 3.2 Centerline S1-34.5 kV 708 easement 712 1986 Pinegrove Ave. Roch. Sta. 425, Irondequoit 34.5 Single circuit, single pole 0.5 Centerline S1-34.5 kV, aerial cable, trim on easement

ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATMENTS Page 2 of 9 CIRCUIT TO VOLTAGE TYPE OF AJPpROXIMATE TYPE OF WIDTH NLBER OF DATE OF LAST FROM OF ROW CIRCUITS ON NUMBER NEXT TREATMENT IN KV CONSTRUCTION LIEN'GTH OF ROW Sta. 412. Roch. 34.5 Double circuit, single pole 5.8 Railroad permit 1 - 115 kV 714 1992 Sta. 7, Roch. 2 - 34.5 kV 34.5 Single circuit, single pole 1.4 Rai troad permit 1 - 115 kV 715 1992 Sta. 412. Roch. Sta. 48, Roch.

Single pole 1 - 34.5 kV Conrail Falls Branch 34.5 Single pole underbuilt 1.1 Railroad permit 1 - 115 kV 716 1988 Sta. 48, Roch. 2 - 34.5 kV City of Roch. on Cir. 916 Sta. 37 34.5 Single pole underbuitt 1.3 Railroad permit 1 - 115 kV 716 1988 Conrail Falls Branch, 1- 34.5 kV City of Roch. on Cir. 916 34.5 Single circuit 2.1 Railroad permit 1 - 34.5 kV 717 1989 Sta. 37, City of Roch. Sta. 22, City of Roch.

Single pole Sta. 91, Brighton 34.5 Single circuit, single pole 1.5 NYS Barge Canal 1 - 34.5 kV, Gas Filled Cable 727 Trim as needed Sta. 56, Pittsford Permit Sta. 42, Roch. 34.5 Single circuit, single pole 2.4 Fee owned Varies 2 - 34.5 kV gas filled catbes, trim 727 Trim as needed Sta. 91, Brighton 4*S 50- 100' Sta. 64, Gates 34.5 Single circuit, single pole 2.5 NMPC permit 1 - 34.5 kV 730 1989 Sta. 67, Chili - 34.5 kV Sta. 114, Gates 34.5 Single circuit, single pole 1.9 Railroad permit 1 730 1989 Sta. 64, Gates 125' 1 - 115 kV Sta. 67, Chili 34.5 Single circuit, single pole 3.2 Fee owned 732 1988 Sta. 37, Roch 1 - 34.5 kV Sta. 114, Gates 34.5 Single circuit, single pole 0.9 Rai lroad permit ---.-. 1 - 34.5 kV 732 1988 Sta. 37 - Sta. 67 R/N Rochester and Chili Sta. 417, Rochester 34.5 Double circuit, single pole 0.5 NYS Barge Canal 2 - 34.5 kV 732 1988 Sta. 37 - Sta. 67 R/N Permit Rochester and Chili Old NY Central Railroad, 34.5 Single circuit, single pole 1.8 Centerline 1 - 34.5 kV 733 1987 Sta. 7, Greece easement Greece 34.5 Single circuit, single pole 1.9 Railroad permit 1 - 115kV 733 1987 Old NY Central Railroad, Long Pond Rd., Greece 1 - 34.5 kV Greece Emerson Rd., Canandaigua 34.5 Single circuit, single pole 2.8 Centerline 1 - 34.5 kV 737 1991 Sta. 168, Manchester easement North Rd., Canandaigua 34.5 Single circuit, "H" frame 0.5 Centerline 1 - 34.5 kV 737 1991 Emerson Rd., Canandaigua easement Railroad, Hopewell 34.5 Single circuit, single pole 1.0 Centerline 1 - 34.5 kV 737 1991 North Rd., Canandaigua easement Sta. 153, Canandaigua 34.5 Single circuit, single pole 1.6 Railroad 1 - 34.5 kV 737 1991 Railroad, Hopewell permit Emerson Rd. & Railroad, 34.5 Single circuit, single pole 1.3 Centertine 1 - 34.5 kV 1991 Sand Hill Rd. & North St.,

Canandaigua easement Canandaigua

ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATMENTS Page 3 of 9 CIRCUIT DATE OF LAST FROM TO VOLTAGE TYPE OF AJ PPROXIMATE TYPE OF WIDTH NLUBER OF NURBER NEXT TREATMENT IN KV CONSTRUCTION LIENGTH OF ROW OF ROW CIRCUITS ON 737 1991 Sta. 428, Canandaigua Ste. 77", Canandaigua 34.5 SingLe circuit, single pole 0.4 Railroad 1 - 34.5 kV permit 738 1991 Ste. 67, Chili Conrai LWestshore Branch, 34.5 Single circuit, single pole 1.3 Fee owned 125' 1 - 115 kV Chili 1 - 34.5 kV 738 1991 Ste. 57, Chili Battantyne Rd., Chili 34.5 Single circuit, single pole 0.5 CenterL ine 1 - 34.5 kV easement 738 1987 Conrail Westshore Branch, Ste. 7470, Rochester 34.5 Single Circuit, single pole 2.3 Railroad 1 - 34.5 kV Chili permit 739 1994 Ste. 56, Pittsford Sta. 76, Pittsford 34.5 Single circuit, single pole 0.9 NMPC permit 2 - 34.5 kV 739 1994 Ste. 76, Pittsford Ste. 9 1, Brighton 34.5 Single circuit, single pole 2.2 Fee owned Varies 1 - 34.5 kV 45' to 100' 1994 Ste. 56, Pittsford Ste. 7 0.9 - 34.5 kV 740 6, Pittsford 34.5 Single circuit, single pole NMPC permit 2 740 1989 Ste. 76, Pittsford Ste. 1 17, East Rochester 34.5 Single circuit, single pole 2.1 Railroad 1 34.5 kV permit 741 1989 Ste. 33, Rochester Ste. 26, Rochester 34.5 Single circuit, single pole 2.2 Railroad 1 - 34.5 kV permit 742 1988 Ste. 48, Rochester Conrai ( Falls Branch, Roch. 34.5 Single pole, underbuitt 1.1 RaiLroad 1 - 115 kV on Cir. 916 permit 2 - 34.5 kV 742 1968 Conrail Falls Branch, Roch. Ste. 86, Rochester 34.5 Single circuit, single pole 1.0 Railroad 1 - 34.5 kV permit 743 1992 Ste. 46, Greece Ste. 4 12, Rochester 34.5 Double circuit, single pole 0.5 Railroad 1- 115 kV permit 1- 34.5 kV 744 1991 Ste. 33, Rochester NYS Berge Canal, Brighton 34.5 Single circuit, single pole 0.7 Fee owned 40' 2 - 115 kV 1- 34.5 kV 744 1991 NYS Barge Canal, Brighton Ste. 82, Brighton 34.5 Single circuit, single pole 1.3 Railroad 1 - 34.5 kV permit 744 NO TREAT NYS Barge Canal, Brighton Ste. 6w6,Brighton 34.5 Underground 1.2 NYS Barge Cana S-----1 - 34.5 kV Permit 745 1994 Drutm Rd., Webster Ste. 4 15, Webster 34.5 Single circuit, single pole 3.8 Fee owned 100' 1 - 34.5 kV 745 1993 ,Emire BlvdL,, Webster Five M Ile Line Rd., Webster 34.5 Single circuit, single pole 1.3 CenterLine --.-- 1 - 34.5 kV Penfield-Tobn Line Penfie IdTown Line easement 745 1991 Across Ir*necduoit Bay in Towns of 34.5 Single circuit "H" frame 0.8 Centertine ----- 1 - 34.5 kV I rond&euoit and Penf etd ger Rd., Ontario and single pole easement 400' 5 - 115 kV 747 1990 Ste. 204, Ontario Clever 34.5 Single circuit, single pole 1.0 Easement 747 1991 Clevenger Rd., Ontario Ste. ,0,Webster 34.5 Single circuit, single pole 2.2 Centertine ..... 1 - 34.5 kV easement 748 1992 Ste. 204, Ontario Monroe -Wayne County Line Rd. 34.5 Single circuit, single pole 2.3 Centerline 1 - 34.5 kV easement 748 1992 Monroe-Wayne County Line Rd. Basket Rd., Webster 34.5 Single pole, underbuitt on 1.3 Fee owned 100' 1 - 115 kV Cir. 909 3 - 34.5 kV

ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATMENTS Page 4 of 9 CIRCUIT DATE OF LAST FROM TO VOLTAGE TYPE OF APPROXIMATE TYPE OF WIDTH NUMBER OF IN KV CONSTRUCTION LENGTH OF ROWt OF ROW CIRCUITS ON NUMBER NEXT TREATMENT 34.5 Single pole, t.derbuitt on 1.8 Fee owned 100' 1 - 115 kV 1992 BtSket Rd., Webster Xerox Prqoerty, Webster Cir. 909 2 - 34.5 kV 748 1992 Xerox PropertyjWebster Sta. 415, Webster 34.5 Single circuit, single pot e 0.7 Fee owed 100' 1 - 34.5 kV Lakeside Rd., Ontario 34.5 Single circuit, single potl e 0.8 Centertine - 34.5 kV 751 out/service North Slocum Rd., Ontario easement Sta. 158, Mt. Morris 34.5 t

Single circuit, single po e 1.6 Centertine - 34.5 kV 753 1982 County Rt. 4, Mt. Morris easement Station 160 34.5 Single circuit, single pot e 1.6 Centertine - 34.5 kV 753 1989 Tallman Rd., Mt. Morris easement Jones Bridge Rd., Leicester 34.5 Single circuit, single pol e 2.0 Fee owned - 34.5 kV 753 1989 Station 160, Mt. Morris Sta. 167, Geneseo 34.5 Single circuit, single pot e 1.1 Centertine - 34.5 kV 753 1989 Route 20 A, Geneseo easement 34.5 Single circuit, single pol e 1.0 Centertine - 34.5 kV 753 1987 Route 20A- Sta. 167, Genesee Sta. 246, Geneseo easement t - 34.5 kV Route 408, Nurida Route 245, Village of Nurda 34.5 Single circuit, single po e 1.4 Centertine 753 1989 easenent Sta. 184, Portage 34.5 Single circuit, single potl e 0.8 Centertine - 34.5 kV 753 1985 Route 245, Portage easement Transit Rd., Genesee Falls 34.5 Single circuit, single pot e 1.7 Centerline - 34.5 kV 753 1985 Route 19A, Genesee Falls easement Route 243, Rushford 34.5 Single circuit, single potl e 0.8 Centertine - 34.5 kV 754 1986 Sta. 247, Rushford easement 100' 1 Sta. 163, Caneadea 34.5 Single circuit, single pot e 3.4 Centertine - 34.5 kV 754 1995 Sta. 180. Houghton easement Sta. 176, Belmont 34.5 Single circuit, single pot e 13.2 Centertine - 34.5 kV, Belmont cut 1994 754 1995 Sta. 163, Caneadea County Route 20, Amity 34.5 Single circuit, single p0ote 2.5 Centerline - 34.5 kV 754 1995 Sta. 176, Amity easement Sta. 7307 34.5 Single Circuit, single pot e 0.5 Centerline - 34.5 kV 754 1995 Sta. 163-Sta. 176 Line, easement Amity Sta. 178, Nile 34.5 Single circuit, single pot e 5.2 Centertine - 34.5 kV 754 1994 County Route 20, Friendship easement Sta. 173, Bolivar 34.5 Single circuit, single pot e 9.5 Centertine - 34.5 kV 755 1994 Sta. 178, Nile easement 167, Geneseo Jones Bridge Rd., Leicester 34.5 Single circuit, single pot e 3.9 Fee owned 100' 1 - 34.5 kV 756 1989 Sta.

Route 19A and Ctaybed Rd., 34.5 Single circuit, single pot e 1.5 Centerline - 34.5 kV 758 1989 Sta. 171, Fillmore Hune easement 1988 Sta. 179, Houghton Sta. 180, Houghton 34.5 "H" frame underbuitt on 0.8 Fee owned 100' 1 - 115 kV 758 1 - 34.5 kV Cir. 907

Page 5 of 9 ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATMENTS CIRCUIT DATE OF LAST FROM TO VOLTAGE TYPE OF APPROXIMATE TYPE OF WIDTH NUMBER OF IN KV CONSTRUCTION LENGTH OF ROW OF ROW CIRCUITS ON NUMBER NEXT TREATMENT Monroe-Wayne County Line 34.5 Double circuit, single poti 2.3 Fee owned 100' 1 - 115 kV 759 1992 Sta. 204, Ontario Road 2 - 34.5 kV Basket Rd., Webster 34.5 Double circuit, single pot, 1.3 Fee owned 100' 1 - 115 kV 759 1992 Monroe-Wayne County Line 3 - 34.5 kV 34.5 Single circuit, single pot, 1.8 Fee Owned 100' 1 - 115 kV 759 1992 Basket Rd., Webster Xerox Property, Webster 2 - 34.5 kV 759 1992 Five Mite Line Rd. at Salt Rd, Webster 34.5 Single pole, single circui 4.0 Centerline --.-- 1 - 34.5 kV easement Penfield-Webster Town Line Sta. 85, Penfield 34.5 Overhead and underground 1.5 Centerline 1 - 34.5k, gas fitted cable 759 Trim only Sta 58, Penfield gas fitted cable easement Sta. 144, Canandaigua 34.5 Single circuit, single pot 1.0 Centerline 1 - 34.5 kV 760 1990 Sta. 155, Canandaigua easement 1990 Middle Cheshire Rd. Sta 7108, Canandaigua 34.5 Single circuit, single pol 1.1 Centerline 1 - 34.5 kV 760 easement Canandaigua Sta. 146. South Bristol 34.5 Single circuit, single pol 9.8 Centertine 1 - 34.5 kV 760 1990 Middle Cheshire Rd.,

Canandaigua easement Seneca Point Rd., Canandaigua34.5 Single circuit, single potl 2.6 Centerline 1 - 34.5 kV 760 1990 Sta. 151, Cheshire easement Sta. 118, Henrietta 34.5 Single circuit, single pot 3.1 Railroad permi t -- 1 - 34.5 kV 761 1988 Sta. 82, Brighton 34.5 Single circuit, single pot 0.6 Centerline -----. 1 -34.5 kV 761 1988 Sta. 75, Henrietta Sta. 82-Sta. 118 Line easement Sta. 80, Henrietta 34.5 Single circuit, single pot 2.5 Fee owned 150' 2 - 115 kV 761 1991 Sta. 416, Henrietta 1 - 34.5 kV Sta. 419, Henrietta 34.5 Single circuit "H" frame 0.7 Easement 150' 1 - 115 kV 761 1991 Sta. 80, Henrietta built 115 kv 1 - 34.5 kV 762 1991 Sta. 91, Brighton Sta. 42, Rochester 34.5 Single circuit, single pot 2.4 Fee owned Varies 2 - 34.5 kV 45' to 100' Clinton Ave. S., Brighton 34.5 Underground 0.9 NYS Barge 1 - 34.5 kV 764 no treat Sta. 66, Brighton Canal Pemit Clinton Ave. S., Brighton Sta. 89, Henrietta 34.5 Single circuit, single pot 1.0 Centerline 1 - 34.5 kV 764 1989 easement Sta. 89, Henrietta Sta. 56, Pittsford 34.5 Single circuit, single pot 2.4 NMPC and 1 - 34.5 kV 764 1989 Railt road Permi t Sta. 46, Greece 34.5 Double circuit, single pot 5.4 Railroad Permi t ---- 115 kv 768 1992 Sta. 7, Greece 2 - 34.5 kV no treat Sta. 425, Irondequoit Rochester-Irondequoit Line 34.5 Underground 0.6 Centerline 1 - 34.5 kV 773 easement 1990 Rochester-Irondequoit Line Genesee River 34.5 Single circuit, single pot 1.4 Railroad Permi t - 34.5 kV I1----

775 Sta. 82, Brighton Sta. 100, Henrietta 34.5 Single circuit, single pot 1.9 NMPC Permit 1 - 34.5 kV 1988

ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATMENTS Page 6 of 9 CIRCUIT DATE OF LAST FROM TO VOLTAGE TYPE OF APPROXIMATE TYPE OF WIDTH NUMBER OF IN KV CONSTRUCTION LENGTH OF ROW OF ROW CIRCUITS ON NUMBER NEXT TREATMENT Empire Blvd., Irordequoit 34.5 Single circuit, single poli e 0.8 Fee owned 40' - 34.5 kV 778 1994 Ste. 43, Rochester - 34.5 kV 1994 Linden Ave., East Rochester 34.5 Single circuit, single po(4e 2.7 Railroad Permit ----

780 Sta. 42, Rochester Centerline ..... - 34.5 kV 780 1986 Ste. 85., Penfield Ste. 7479, Rochester 34.5 Single circuit, single poli e 0.4 easement Ste. 121, Macedon Ste. 120, Macedon 34.5 Single circuit, single poi e 2.0 Easement ..... - 34.5 kV 782 1991 built 115 kV Victor Rd. At Macedon 34.5 Single circuit, single poot e 1.0 Centertine ..... - 34.5 kV 782 1988 Ste. 120, Macedon Farmington Town Line built 115 kV easement Bowerman Rd. At Brownvilte Hook Rd., Fanmington 34.5 Single circuit, single pot e 1.4 Centertine - 34.5 kV 782 1990 Rd., Farmington easement Ste. 777, Canandaigua 34.5 Single circuit, steel 8.1 Centertine - 34.5 kV 782 1991 Ste. 154, Victor towers & single wood poles easement Buell Rd. Canandaigua 34.5 Single circuit, single pot e 1.5 Centertine - 34.5 kV 782 1991 Brickyard Rd., Canandaigua easement Ste. 152, Holcomb 34.5 Single circuit, single potae 2.2 Centerline ..... - 34.5 kV 782 1991 Buell Rd., East Bloomfield easement 34.5 Single circuit, single pot e 2.0 Centertine ..... - 34.5 kV 782 1991 Ste. 152, Holcomb Ste. 145. East Bloomfield easement Whaten Rd., East Bloomfield 34.5 Single circuit, single pot e 1.0 Centertine ..... - 34,5 kV 782 1991 Ste. 152-Sta. 145 Line easement 1992 Ste. 204, Ontario Monroe-Wayne County Line 34.5 Double circuit, single pot e 2.3 Fee owned 100' - 115 kV 789 - 34.5 kV built 115 kV 34.5 Double circuit, single pot e 1.3 Fee owned 100' - 115 kV 789 1992 Monroe-Wayne County Line Basket Rd., Webster built 115 kV - 34.5 kV Road 1992 Basket Rd., Webster Ste. 424, Webster 34.5 Single circuit, single pot e 1.7 Easement Normally - 34.5 kV 789 60' built 115 kv - 34.5 kV i989 Ste. 7470, Rochester Union St., Chili 34.5 Single circuit, single pot e 2.7 Railroad permit ----

792 Railroad permit ---- - 34.5 kV 792 1989 Union St., Chili Trabold Rd., Chili 34.5 Single circuit, single pot e 4.2 1989 Ste. 216, Sodus Ste. 210, Sodus 34.5 Single circuit, single pot e 0.6 Centertine .....

794 easement 1989 Mapte St., Sodus State St., Sodus 34.5 Single circuit, single pot e 0.6 Centertine - 34.5 kV 794 easement Ste. 209, Sodus Point 34.5 Single circuit, single pot e 1.7 Centerline ..... - 34.5 kV 794 1989 Mudd Lard Rd., Sodus easement Ridge Rd., East of Alton 34.5 Single circuit, single pot e 2.3 Centerline ..... - 34.5 kV 794 1989 Boyd Rd., Sodus easement 1989 Sta. 216, Sodus Ste. 210, Sodus 34.5 Single circuit, single pot e 0.6 Centertine ..... - 34.5 kV 795 easement 795 1989 Ste. 210, Sodus Ste. 196, Alton 34.5 Single circuit, single pot e 5.0 Centerline ..... - 34.5 kV easement

Page 7 of 9 ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS ANDSCHEDULE OF TREATMENTS TYPE OF WIDTH NUNMER OF CIRCUIT DATE OF LAST FROM TO VOLTAGE TYPE OF APPROXIMATE IN KV CONSTRUCTION LENGTH OF ROW OF ROW CIRCUITS ON NUMBER NEXT TREATMENT 0.5 Centerline 1 - 34.5 kV 795 1989 Ste. 196, Alton Brockhaven Rd., Sodus 34.5 Single circuit, single pole 34.5 Single circuit, single pole 0.8 Centertine 1 - 34.5 kV 795 1989 Railroad, Wolcott Sta. 192, Wolcott 34.5 Single circuit, single pole 1.8 Centertine 1 - 34.5 kV 796 1995 Sta. 214, Wiliamson Ste. 208, E. Williamson easement 34.5 Single circuit, single pole 4.0 Centertine 1 - 34.5 kV 796 1995 Sta. 208, E. Williamson Ste. 216, Socus easement 34.5 Single circuit, single pole 0.8 Centertine 1- 34.5 kV 796 1989 Route 104, Williamson Sta. 207, Williamson easement Single circuit, single pole 1.6 Centertine 1 - 34.5 kV 796 1989 Sta. 207, Williamson Eddy Ridge Rd., Williamson 34.5 easement 34.5 Single circuit, single pole 2.4 Centertine 1 - 34.5 kV 796 1989 Batl Rd., Marion Ste. 193, Marion easement 34.5 Double circuit, single pole 6.2 Fee owned 1 - 34.5 kV 797 1988 Ste. 202, Williamson Ste. 216, Sodus 1 - 115 kV 115 kV Rights-of-Way Mortimer, Ste. 82, Brighton Sta. 33, Rochester 115 Single circuit, steel 2.1 Fee owned 40' 2 - 115 kV 901 1991 1 - 34.5 kV towers and wood poles 115 Single circuit, single pole 1.9 Fee owned 40' 2 - 115 kV 902 1991 Mortimer, Ste. 82, Brighton Ste. 33, Rochester 1 - 34.5 kV Sta. 67, Chili 115 Double circuit, single pole 2.1 Fee owned 50' 2 - 115 kV 903 1987 Ste. 82, Brighton 150' 3 - 115 kV 1991 Ste. 80, Henrietta Ste. 82, Brighton 115 Single circuit, "H" frame 3.4 Fee owned

/904 1 - 34.5 kV 115 Single circuit, "H" frame 3.5 Fee owned 150' 3 - 115 kV

/ 905 1991 Ste. 80, Henrietta Ste. 82. Brighton 1 - 34.5 kV 115 Single circuit, "H" frame 36.0 Centertine 1 - 115 kV 906 1986 - 1988 Ste. 82, Brighton Ste. 162, Perry easement &

Railroad permil Ste. 180, Hume 115 Single circuit, "H"frame 23.9 Centertine 1 - 115 kV "V 907 1967 - 1988 Ste. 162, Perry easement, Fee owned 100' 1 - 34.5 kV 13.9 Fee owned & Varies 5 - 115 kV

/908 1990 Sta. 13A, Ontario Ste. 230, 121, Macedon 115 Single circuit "H" frame easement 300' - 400'1 - 34.5 kV 115 Single circuit, single pole 8.0 Fee owned & 400' 5 - 115 kV 1 909 1990 Ste. 13A, Ontario Ste. 204, 230, Macedon easement 2 - 34.5 kV

R7 S O Page 8 of 9 ROCHESTER GAS AND ELECTRIC CORPORATION, 0EZA1i<PION OF CROSS CCUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATM4ENTS FROM TO VOLTAGE TYPE OF APPROXIMATE TYPE OF WIDTH NUMBER OF CIRCUIT DATE OF LAST CONSTRUCTION LENGTH OF Raw OF ROW CIRCUITS ON NUMBER NEXT TREATMENT IN KV 115 Single circuit, single potLqD 4.8 Fee owned & 100' 1 - 115 kV 1/909 1992 Sta. 204, Ontario Ste. 424, Webster 34.5 kV easement 3 -

L* 100' 1 - 115 kV 115 Double circuit, single pot e 12.2 Fee owned

/ 909 1988 Slocum Rd., Ontario Ste. 216, Sodus 1 - 34.5 kV t* 50' 1 - 115kV Sta. 418, Gates 115 Double circuit, single pot e 3.5 Fee owned

/ 910 1987 Sta. 67, Chili 1 - 34.5 kV 115 Single circuit, "H" frame 12.1 Fee owned & 400' 5 - 115 kV 1990 Ste. 13A, Ontario Sta. 230, 124, Penfield easement 2 - 34.5 kV Underground 1.4 Easement 15' 2 - 115 kv V 911 1981 Jackson Rd. Penfield Five Mile Line Rd., PenfieLd 115 1.3 Easement 15' 2 115 kV 1911 No Treatment BLossom Rd., Penfield Larding Rd., Brighton 115 Underground 115 Single circuit, "H" frame 18.1 Fee owned & Varies 5 - 115 kV 1990 Sta. 13A, Ontario Sta. 204, 230, 121, 122, Perinton easement 300' - 400'2 - 34.5 kV 115 Single circuit, "H" frame 12.1 Fee owned & 400' 5 - 115 kV 1990 Sta. 13A, Ontario Ste. 230, 124, Penfield easement 2 - 34.5 kv 115 Underground 1.4 Easement 15' 2 115 kV 913 1981 Jackson Rd., Penfield Five Mile Line Rd., Penfield 115 Underground 1.3 Easement 15' 2 -115 kV 913 No Treatment Blossom Rd., Penfield Lending Rd., Brighton 115 Single circuit, "H" frame 3.4 Easement 400' 2 -115 kV

/ 914 1990 Ste. 121., Macedon Ste. 122, Perinton Brooks Ave. Gates 115 Underground 0.5 Fee owned 125' 1 " 115 kV 916 1988 Ste. 67, ChiLi 1 " 34.5 kV 115 Single circuit, "H" frame 4.8 Fee owned& 125' 916 1988 Brooks Ave, Gates Sta. 37, 48, Rochester

& single pole Railroad permi t -----.

L Fee owned 80 1 -115 kV Sta. 71, Parma 115 Single circuit, single pol e 6.7

/ 917 1987 Sta. 7, Greece 1 - 34.5 kV l 1.5 NYS Barge 1 -115 kV

/ 917 1987 Gillett Rd., Ogden Specnerport Ste. 115 Single circuit, single pot e Canal Permit t Centertine 1 115 kV Ste. 418-Sta. 113 R/U 115 single circuit, single pol e 3.4

/ 917 1992 Spencerport Sta. easement Ste. 113, Ogden 115 Single circuit, "H" frame l 1.0 Fee owned 150' 2 - 115 kV 917 1992 Spencerport Tap 150' 2 - 115 kV Spencerport Tap 115 Single circuit, single po e 1.0 Fee owned 917 1092 Ste. 113, Ogden 1 - 115 kV Sta. 418, Gates 115 Single circuit, "nH"frame 2.3 Fee owned 50'

/ 917 1992 Spencerport Tap 0.7 Easement 150' 1 - 115 kV Sta. 419, Henrietta 115 Single circuit, "H" frame 918 1991 Ste. 80, Henrietta 1 - 34.5 kV l 7.5 Railroad permi t 1 - 115 kv 1----

1992 Ste. 7, Greece Sta. 48, Rochester 115 Single circuit, single po e 919 2 - 34.5 kV Le 1.5 Fee owned 125' 1 - 115 kV 921 1985 Ste. 67, Chili Conrail Westshore, Chili 115 Single circuit, single po 1 - 34.5 kV 115 Single circuit, "H" frame & 3.1 Centerline ----. 2 - 115 kV 921 1986 Conrail Westshore, Chili Ste. 82, Brighton Single pole easement & 1 - 34.5 kV Fee owned 50'

ROCHESTER GAS AND ELECTRIC CORPORATION, DESCRIPTION OF CROSS COUNTRY RIGHT-OF-WAY SECTIONS AND SCHEDULE OF TREATMENTS Page 9 of 9 VOLTAGE TYPE OF APPROXIMATE TYPE OF WIDTH NUMBER OF CIRCUIT DATE OF LAST FROH TO IN KV CONSTRUCTION LENGTH OF RW OF ROW CIRCUITS ON NUMBER NEXT TREATMENT 115 Single circuit, single pole 3.0 Fee owned 50' 1 - 115 kV 921 1987 Conrail Westshore, Chili Sta. 104, Chili Fee owned 150' 3 - 115 kV

/922 1991 Sta. 80, Henrietta Sta. 82, Brighton 115 Single circuit, "H" frame 3.4 1 - 34.5 kV Monroe County Airport 115 Double circuit, single pole 1.9 Fee owned 50' 2 - 115 kV 922 1987 Sta. 82, Brighton 50o 1 - 115 kV 922 No Treatment Monroe County Airport Sta. 67, Chil 115 Underground 0.5 Fee owned

FIGURE i ROW MANAGEMENT PLAN REPORTING RELATIONSHIPS DIVISION MANAGER. ENERGY DELIVERY

ROCHESTER GAS AND ELECTRIC CORPORATION ELECTRIC FRANCHISE AREAS LAKE ONTARIO PORTOF I FIkpTO RINTON ORRIS j

LEGEND I CANANDAIGUA DISTRICT- YELLOW LAKE SHORE DISTRICT-ROCHESTER DISTRICT - RED GENESEE DISTRICT -

GREEN BLUE ALLEGANY OF NEW YORK STATE OF PENNSYLVANIA Fiourp A

NYPP NEW YORK POWER POOL CENTRAL HUDSON GAS A ELECTRIC CORPORATION NIACARA MOHAWKPOWERCORPORATION CONSOLIDATED EDISON CO. OF NEW YORK, INC. ORANGEANDROCKLAND UTILITIES,INC.

LONGISLANDLIGHTINGCOMPANY NEWYORKPOWERAUTHORITY NEWYORKSTATEELECTRIC& GASCORPORATION ROCHESTER GASANDELECTRIC CORPORATION Coordloatod by NYPP Planning Staff 1993 N t L+/-?,bAV rat r KJSSIVLLI I AN WERI'TLAND IiRd No.rh Toni oc "P0 W41LLI SIAN 4A

-r WE rnLL\y 4

K EmOI CAT NY OtAj

-#I NEW UElE DWýARXEN T6F 7+/-WA;1A

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7 NEW YORK STATE MAP zle -.

STATIONS GENERATMO TRANSMI¢SSION ASWO UNrEs II anS ELECTRIC SERVICE AVEAS W, UUALIRC* MS.EISa EVIcrEC SSSflI .OMI+/-.ao.,tRV C ;0 PALLS

- U*S1IItPC

______ ,SVASO .tflflU non" r ID IACTBiSLDOVVA7VV IVMIEAAUSA

-~WEST HERSTER N - U lfIES

  • M STAT

ew* ht TRAMISSIO STATIONS 0.nkiVSoqaN 0, 2,M00. Oil 51 aiR SCALE12,LO.000

ý,A'T L - JV-r'IC , 0,CPE Fiaurp2

LIST OF FIGURES ROW 1- 12 RG&E ELECTRIC FRANCLISE ROW SYSTEM MAPS NOT REVISED SEE JANUARY 1981 REVISION

Exhibit 1 ROCHESTER GAS and ELECTRIC CORPORATION AERIAL INSPECTION REPORT - DATE FLOWN PATROL #: DISTRICT: INSPECTOR:

AERIAL I STRUCTURE I TREE I ELECT. MECH. I REMEDIAL DATE LOC.NO NUMBER CONDITION CONDITIONS ACTION TAKEN COMPLETE REMARKS:

ONE COPY OF COMPLETED REPORT TO: RIGHT-OF-WAY MGT. COORDINATOR PC:LOTUS/APMASTER

Exhibit 2 ROW MAINTENANCE AND VEGETATION FIELD INSPECTION DATA SHEET AND INVENTORY REPORT GENERAL Circuit Number ----------------------------------------------------

Patrol No. ----------------------------------------------------

From Sta. ----------------------------------------------------

To Sta. ----------------------------------------------------

Common Lines ----------------------------------------------------

Inventory Date ----------------------------------------------------

USGS Map Designation ----------------------------------------------------

Wetland Map Designation ----------------------------------------------------

LOCATION Site No. ----------------------------------------------------

From Pole ----------------------------------------------------

To Pole ----------------------------------------------------

Total Acres - ----------------------------------------------------

LAND USE/DENSITY Orig. Cut - 1 or 2 ----------------------------------------------------

Land Use - I thru 5 ----------------------------------------------------

Compatibility - 1 thru 3 ----------------------------------------------------

Density - 1 thru 3 ----------------------------------------------------

TREATMENTS Chem. Treatment Type Mech. Treatment Type Desirables Species Undesirables Species Height REMEDIAL Danger Trees Side Trimming Streams/Roads -

Expected Treatment Date -

Comments - ----------------------------------------------------

abbrevations: HA-hydro axe FS-foliar spray WR-windrow HC-hand cut BS-basal spray CH-chip SIT-side trim BS*- pre-treat LD-lop & drop SET-selective trim PC-pile & crush NT-no treatment ST- stump treat Pc:Lotus:Inventory

EXHIBIT 3 ELECTRONIC SITE SPECIFIC CIRCUIT INVENTORY Circuit Number: 755 - NiLe to Bolivar Patrol Number:

Station From/To: 175-173 Common Line:

Estimated Year of Treatment: 1993 Inventory Date: 4/27/93 Inventoried By: J. Pasquini, R. O'Brien Multiple Use: Hiking, fishing, camping Primary Objectives: Economical end ReliabLe service Mech:HA,NC,SIT,SET7NT Secondary Objectives: Environmental compatibility Chem: FS,ST,BS USGS/Wetland Map: Site:CHWARLD Site Pole to PoLe Site Site Site Site

  • Site LAST Site Chemical Date of Desirable UndesirabLe AVE/MAX Number Numbers Length Width Acres Land use Treatment Disposalozs./gts. Treatment TREATMENT Vegetation Vegetation HEIGTH Comments 1 PI-23 5082 80 9.33 1421.00 BS,HC,ST NC,ST KA DOGWOOV, B6UCKTHORIAPPLE POPLAR,ASN,1APLE 5/25 P1-8 PARALLELS NMPC34.5 LINE SUMAC WIDEN TO 80', SMALL POND AT PIS,P22-23 WIDEN PINES 2 P23-26 838 80 1.54 1410.00 NA NA NA NA NA NA AG FIELD 3 P26-27 354 80 0.65 1121.00 HC,ST,BS HC LD SUMAC,WILLOW,HAWTHORN POPLAR, CERRY ,WILLOW 10/20 STREAMCROSSING 4 P27-29 639 80 1.17 1410.00 HC,ST,BS HC LD AC ASH 15/20 AG FIELD 5 P29-54 4742 80 8.71 1522.00 HC,ST,BS HC LD HAWTHORN,GRASS,DOGPOP,NAPLE,PINE 15/20 P33-34 CREEK,P46 CREEK 6 P180-191 1957 8s 3.59 1410.00 NT NT NA NA NA NA P185 SIDE TRIM WHITE PINE P190 ANCHOR AROND DEADSTUMP,REMOVE 7 P191-199 1396 80 2.56 1411.00 HCSTBS K1C LD HAWTNORHE,SHADPASTURE CHERRYPINEMAPLE 15/30 WIDEN HIGH SIDE TO 404 STREAM ANDPASTURE,P196 SIDE TRIM MAPLES 8 P199-213 2310 80 4.24 1522.00 HC,ST,BS HC,ST LD HOWEYSUCKLE,DOGOOD, HAWTHPINE,CHERRY,MAPLE 15/25 WIDENHIGH SIDE TO 40'

Exhibit 3, page 2 Site Pole to Pole Site Site Site Site Site LAST Site Chemical Date of Desirable Undesirabie AVE/MAX Number Numbers Length Width Acres Land use Treatment TREATMENT Disposatozs./gLs. Treaument Vegetation Vegetation HEIGTN Comments 9 P213-219 1206 50 1.38 1312.00 HC,SET MC,SET CR LA.A,APPLE CHERRYTAPLE.PINE 40/60 SEE ABOUTREMOVING

=K TREES 10 P250-252.5 405 80 0.74 1411.00 BSBCST HC,ST MT DOG,6HAMTMON POP,CRERRY, 10/45 11 p252.5-262 1635 80 3.00 1410.00 HT NT MT AG NONE MAYFIELD 12 P262-266.5 832 80 1.53 1411.00 BS,I*C,ST HC MT HAWTHORN.lOXEY,DOG CEERRTWI LLOW,HAPLE 10/20 P264.5 CREEK, 13 P266.5-STA 173 713 80 1.31 1421.00 BSKCST HCST LD DOGHONEYGRASSES POP, 15/20

"**ROAD NOTES*" SITE P225 REMOVE ONE STEM OF UILLOU LANDUSE P229 TRIM PINE P230-234 HC.ST CREEK AT P230 First Digit 1,000 Selectivel Cut 2,000 Originaly Clearcut Second Digit " 100 Lakes, Ponds, Wetlands 200 Comercial, Industrlal TOTALS 300 Residential, Lews 400 Brush Fields, Pasture, Farm Lands LINEAR DISTANCE (ft) 22,109 500 Wooded Areas ACRES (80' ROW) 39.77 Third Digit - 10 Coepatible (1001 coepatible) 20 Semi-oepatibie (up to 50% non-compatible)

HANDCUT STUMP TREAT (ft) 16,473 (WIDENEXISTING ROW FROI SO TO 80') 30 Non-coeptlble (greater than 50% ron-compatible)

HANDCUT NO TREAT (ft) 1,206 Fourth Digit 1 Light (Less than 302 Non-compatibie) Density I

BASAL SPRAY (Acres) 18.91 (BASAL SPRAY EXISTING ROW50' WIDE) 2 medium C301 % Non-carpatibLe) Density NOTREAT (Acres) 8.14 3 Neavy (Greater than 701 Non-compatibLe) Density

Exhibit 4 RG&E RIGHT-OF-WAY MAINTENANCE ACTIVITIES 1979 - 1993 YEAR METHOD EMPLOYED ACREAGE TREATED COSTIACRE 115kV 34.5kV 1979 METHOD A 22.5 $295.00 METHOD D 74 195.00 METHOD F 74 95.00 1980 METHOD A 301 41 407.50 METHOD D 53 53 287.50 METHOD F 39 39 167.93 1981 METHOD A 60 175.00 METHOD B 6 175.00 METHOD D 105 55 142.00 1982 METHOD A 20.5 20.5 480.00 METHOD A* 65 20 304.00 METHOD F 140 7.5 218.00 1983 METHOD A 87.5 87.5 305.00 METHOD A* 45 450.00 METHOD D 52 110.00 METHOD F 131.5 180.00 1984 METHOD A 145 106 374.00 METHOD A* 55 49 446.00 METHOD D 92.25 160.00 METHOD F 70.8 254.00 1985 METHOD A 83 83 479.91 METHOD B 10 250.00 METHOD D 141 241.50 METHOD F 61.25 246.47 1986 METHOD A 130.25 97 482.95 METHOD A* 7.10 2.1 525.00 METHOD B 6.0 508.00 METHOD D 74.23 300.00 METHOD F 72.05 403.10 1987 METHOD A 173.49 36.19 506.70 METHOD A* 11.62 6 392.25 1988 METHOD A 159.44 318.80 METHOD A* 25.80 361.10 METHOD B 51.29 650.00 METHOD F 58.00 293.53

Exhibit 4 PAGE 2 RG&E RIGHT-OF-WAY MAINTENANCE ACTIVITIES 1979 - 1993 YEAR METHOD EMPLOYED ACREAGES TREATED COST/ACRE 115kV 34.5kV 1989 METHOD A 86.40 549.00 METHOD SIT 16.11 MILES 3408.00/MI ROC. & GV METHOD F 227.00 227 144.00 LS 1990 METHOD A 81.40 61.17 703.00 METHOD A* 73.81 1.74 291.00 METHOD B 218.51 146.63 METHOD D 2.50 480.00 METHOD F 39.75 274.21 1991 METHOD HC,ST 13.09 312.00 METHOD BS 107.30 142.50 METHOD HC,ST,SIT 62.47 62.47 1,476.55 1992 METHOD HC,ST 87.00 64.9 256.42 METHOD HC 6.08 205.00 1993 METHOD HC,ST 74.07 1049.00 WIDENING METHOD HC 10.33 222.00 METHOD BS 160.55 231.84 Method A or HC,ST - hand cut with stump treatment Method A* or HC - hand cut Method B or BS - basal Method B* or BS* - pre-treat Method D or FS - foliar Method F or HA - mow Method SIT - side trim Note: Treatment codes revised in 1991 (ie: Method A now HC,ST - ETC.)

PC:WORD:DIVISION COSTS

ROCHESTER GAS AND ELECTRIC CORPORATION

  • 89 EAST AVENUE, ROCHESTER, N.Y. 14849-0001 EXHIBIT 5 DATE TELEPHIONE AREA CODE 716 546-2700 Ref: Transmission Circuit #XYZ Pesticide Notification - RG&E Electric Transmission Maintenance Program

Dear Customer:

New York State Legislation requires written notice to be provided to occupants of a residence prior to the application of a pesticide on their land. Since the Rochester Gas and Electric's vegetation management program requires that the vegetation on the right-of-way easement over or along your property receive periodic herbicide treatment, the manufacturers' herbicide labels are enclosed with this letter in compliance with this legislation.

The Rochester Gas and Electric's right-of-way management program is based on a vegetation management system according to which those trees and shrubs capable of causing electrical interference are discouraged or eliminated. To accomplish this task, the selective application of carefully chosen herbicides has been a major part of the Rochester Gas and Electric's right-of-way vegetation management program. Properly applied, herbicides provide for safe, cost effective vegetation management and allows us to encourage the development of a stable, low-growing plant community which will minimize the future use of herbicides.

The enclosed manufacturers' herbicide labels identify and discuss the specific herbicides intended for use on the RG&E easement that crosses or runs along the side of your property. Should you have any questions, please call me at 716/771-4418.

Very truly yours, Joseph F. Pasquini System Forester Date:

Notice Served By Address or Location of Notice Hand Delivered To Occupant /_/

Left At Door /_/

Mailed /_

Pc: Pest

EXHIBIT 5, PAGE 2 Pesticide Application Notification COMMERCIAL APPLICATOR NOTIFICATION COVER SHEET Rochester Gas and Electric Corporation, pursuant to the requirements of the New York State Department of Environmental Conservation, must give notice when herbicides will be applied to control incompatible vegetation on easement rights-of-way when the application will be within 100 feet of a residence or other occupied building of structure.

The right-of-way near your residence has been scheduled for a herbicide application Timing of the application - The application will be started between 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and one week from the delivery of this notice. However, adverse weather conditions can cause delays. Should weather conditions cause a delay, the application will be performed as soon as weather permits, and you will be notified of the application having been made by the posting of a sign in the vicinity of the herbicide-treated area.

Herbicides To Be Applied - The following herbicide (s) will be applied: ,

The application method is noted below, in accordance with the attached label(s).

Application Method - The application method is checked below. In all cases, the application will be made by hand-held equipment.

Stump Treatment - The cut surface of the freshly-cut stump will be treated. Depending on the material applied, it may be necessary to treat the bark and exposed roots.

Basal Treatment - The bottom 12-18 inches of the trunks of the target trees will be treated.

Low Volume Foliar - The leaves of the target trees will be treated.

Other Re-Entry Into Treated Areas - The label(s) for the herbicide(s) being applied do not require that a waiting period be observed before re-entering the right-of-way. However, if a foliar treatment has been made, it is suggested to wait until the spray has dried before re-entering the right-of-way.

EXHIBIT 5, PAGE 3 Application Information - The application will be performed under the guidance of a New York State certified pesticide applicator.

The company name and Pesticide Business Registration Number of the firm making the application is:

Applicator Business Name Pesticide Business Registration No.

Phone Number For More Information - If you desire more information concerning this application, please contact your local DEC Regional office.

The New York State DEC Regional Office are listed below:

Region 7 - Broome, Cayuga, Chenango, Cortland, Onondaga, Oswego, Madison, Tioga, Thompkins Counties; Box 5170, Cortland, New York 13045 Phone 607-753-3095 Region 8 - Chemung, Genesee, Ontario, Livingston, Monroe, Yates, Wayne, Schuyler, Seneca, Steuben Counties; Savings and Loan Building, Box 315, 115 Liberty Street, Bath, New York 14810 Phone 607-776-2165 or 6274 E. Avon-Lima Road, Avon, New York 14414 Phone 716-226-2468 Region 9 - Allegany, Cattaraugus, Niagara, Chautaugua, Erie, Wyoming Counties; 600 Deleware Avenue, Buffalo, New York 14202 Phone 716-874-4585 or 215 S.Work Street, Falconer, New York 14733 Phone 716-665-6111 NYS POISON CONTROL CENTERS (W. NEW YORK)

Area 1 - Western New York Poison Control Center at Buffalo Childern's Hospital, 219 Bryant Street, Buffalo, New York 14222 Phone 716-878-7654 (Allegany, Cattaraugus, Chautaugus, Erie, Genesee, Niagara, Orleans, Wyoming Counties)

Area 2 - Finger Lakes Poison Control Center, University of Rochester, 601 Elmwood Avenue, Box 321, Rochester, New York 14642 Phone 716-275-5151 (Chemung, Livingston, Monroe, Ontario, Schuyler, Seneca, Steuben, Wayne, Yates Counties)

Area 3 - Central New York Poison Control Center, University Hospital, SUNY Health Science Center, 750 East Adams Street, Syracuse, New York 13210 Phone 315-476-4766 (Cayuga, Cortland, Herkimer, Jefferson, Lewis, Madison, Oneida, Onondaga, Oswego, St.Lawrence, Tompkins Counties)

EXHIBIT 6 PESTICIDE NOTIFICATION LOG CONTRACT/CIRCUIT: Methods of delivery:

M - Mailed COMPANY: H - Hand delivered D - Left at door ADDRESS NAME OF OCCUPANT DATE TIME METHOD OF DEL. L

SHEET NO.

44-14-15 (6/77) NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION BUREAU OF PESTICIDES - ALBANY, NEW YORK 12233 IiEXHIBITj_7 YEAR CERTIFIED COMMERCIAL APPLICATOR RECORD OF PESTICIDE PURCHASE AND USE LIST ALL RESTRICTED USE PESTICIDES PURCHASED ACCORDING, TO TRADE NAME AND EPA REGISTRATION NUMBER ON THE BACK OF THIS FORM.

NAME OF CERTIFIED APPLICATOR AADDRESS CERTIFICATION I.D. NO.

LIST SEPARATELYiBELOW ALL PESTICIDES USED.

APPLIqATION DATA NAME OF PESTICIDE USED AND TARGET Quantity Place or Places where Rate of Application DATE(S) TREATED EPA REGISTRATION NO. ORGANISM Used Pestic ide was appilied Method or Dosage ____________

Appendix I LAND USE CODES A system of land use codes is used to aid in the description of a number of different characteristics found on RG&E ROW system. It is, in essence, the baseline data bank. The codes are the tool used in the inventory process.

The first digit can range between 1 and 2 and denotes whether the ROW was originally clearcut for construction or whether it was selectively cleared.

  • 1,000 Selectively Cut
  • 2,000 Originally Clearcut The second digit ranges from 1 to 5 and indicates the type of land crossed by the ROW, or how that land is being used.

100 Lakes, Ponds, Wetland 200 Commercial, Industrial

  • 300 Residential, Lawns 400 Brush Fields, Pasture, Farm Lands
  • 500 Wooded Areas The third digit ranges from 1 to 3 and identifies the relative proportion of non-compatible species present on the ROW.

1 Compatible (100% compatible) 10

  • 20 Semi-compatible (up to 50% non-compatible) 30 Non-compatible (greater than 50% non-compatible)

The fourth digit ranges from 1 to 3 and indicates the relative density of the undesirable vegetation present on the ROW.

  • 1 Light (Less than 30% Non-compatible) Density
  • 2 Medium (30% - 70% Non-compatible) Density
  • 3 Heavy (Greater than 70% Non-compatible) Density The last three digits can be combined as follows:

-100 Lakes, ponds, swamps, no maintenance required

- 10 Compatible (Scattered brush and trees)

- 20 Semi-compatible

- 30 Non-compatible

- 1 Light

- 2 Medium

- 3 Heavy I-I

-200 Commercial - Industrial

- 10 Compatible (landscaping, low ornamentals, hedges, etc.)

- 20 Semi-compatible (landscaping, low and tall ornamental)

- 30 Non-compatible

- 1 Light

- 2 Medium

- 3 Heavy

-300 Residential

- 10 Compatible (low ornamental, hedges, etc.)

- 20 Semi-compatible (mixed species, i.e., specimen hardwoods, pine, spruce, fir, etc.)

- 30 Non-compatible (poplar, ash, locust, high conifers, etc.)

- 1 Light (lawn, small ornamentals or few trees to be trimmed)

- 2 Medium (semi-landscaped, i.e., woods area, orchards, etc.)

- 3 Heavy

-400 Brush fields, pasture, farm lands, etc.

- 10 Compatible (truck farm crops, pasture, open fields, etc.)

- 20 Semi-compatible (hedgerows, orchards, brush fields, etc.)

- 30 Non-compatible (overgrown fields, high orchards, etc.)

- 1 Light

- 2 Medium

- 3 Heavy

-500 Wooded areas

- 10 Compatible (low growing species, i.e., laurel, viburnums, witch hazel, etc.)

- 20 Semi-compatible mixed species, i.e., dogwood, shadbush, ash, maple, etc.)

- 30 Non-compatible (maple, ash, locust, birch, oak, sassafras, etc.)

- 1 Light (heavily grassed, scattered patches of growth)

- 2 Medium (30% to 70% covered with growth)

- 3 Heavy (70% to 100% covered with growth)

The numbers 100 to 500 describe present land use types.

"100 - Lakes, ponds, swamps, no cutting required": A section of ROW containing a lake, pond or swamp is noted under the ROW Maintenance Program. These sections usually require no cutting of woody vegetation; however, there are cases where closeness of the shoreline of a lake may require some trimming. These cases are noted on the ROW maintenance plan. In no case shall motor oil or gasoline used for line clearing equipment, or any other refuse be allowed to enter lakes, ponds, swamps, marshes and/or 1-2

their streams. Herbicides, in their oil carriers, will still be allowed to be used in these areas, but on a case by case basis.

"200 - Commercial - Industrial": Commercial-Industrial areas include business offices, factories, shopping centers, parking lots, warehouses, railroad yards, highways, gas stations, etc.

Usually most of the vegetation is of low aesthetic value and incompatible with conductor heights and may be completely removed.

However, some shopping centers, business offices and highways have been landscaped or contain vegetation that should be retained for aesthetic appeal. These areas usually warrant "selective trimming." Wood and brush are usually chipped and removed from treatment sites.

"300 - Residential" Residential areas include single family homes as well as apartments, condominiums, townhouses, small community parks and recreational areas. A single general store of gas station or other small community business is considered part of the residential area.

Since residential areas are most often in public view, careful clearing practices must always be exercised. Usually chemical herbicides should not be used in these areas. In residential areas "Selective Hand Cut - No Chemical Stump Treatment" or "Selective Trimming" will be the most common clearing methods employed. Wood and brush are usually chipped and removed from treatment sites.

"400 - Brush fields, pasture, farmlands, etc.": Abandoned pastures supporting invasion species and other inactive farmland, as well as agricultural land presently in use, are included in this type.

Farmers often use hedgerows (a narrow row of trees along a rock wall or fence) to divide the farmland. Transmission line sections crossing hedgerows usually require "Selectively Cut - No Chemical Stump Treatment" and "Side Trimming". No chemical herbicide should be used on active farmland without the permission of the owner, as herbicide may damage nearby crops. Treatments include both chemical and non-chemical methods. Wood and brush disposal techniques include lop and drop, hand cut and pile.

"500 - Wooded Areas". All mature or semi-mature forests and lands which are wooded and do not fit into any of the above categories are included in this type. Treatments include all chemical and non-chemical treatments and all disposal techniques.

The numbers 10 30, and 1 3 indicate vegetation compatibility and density, respectively:

"10 - Compatible": This vegetation type is known as non-target, low growing desirable species and includes landscaping, low growing ornamentals and hedges in "200 - Commercial, Industrial" areas; vegetables, flowers, fruit trees, ornamental shrubs, etc.

1-3

in "300 - Residential" areas: truck farm crops, pasture, open fields, etc., in "400 - Brush Field" areas: dogwoods, viburnums, witch hazel, etc. in "500 - Wooded Areas." Generally no treatment is required until undesirable species become established.

"20 - Semi-compatible": This vegetation type includes a mixture of compatible and non-compatible species. In "200 - Commercial Industrial" areas, semi-compatible species may be due to landscaping with low and tall growing ornamentals; in "300 Residential" areas, semi-compatible species may be specimen hardwood and softwood ornamentals; in "400 - Brush Fields", semi compatible species may be hedgerows, orchards and brush fields; in "500 - Wooded Areas" semi-compatible species may be a mixture of dogwood, shadbush, ash and maple, etc. Locations having semi compatible vegetation will require selectivity in cutting and chemical application during ROW maintenance procedures.

"30 - Non-compatible": This vegetation type is also referred to as target, tall-growing or undesirable species. Non-compatible species include those trees such as ash, oak, maple, poplar, elm, hickory, black locust, ailanthus, etc.

"I - Light": Less than 30% covered with woody vegetation.

"2 - Medium": Woody vegetation covering between 30% - 70% of the ROW.

"3 - Heavy": Woody vegetation covering over 70% of the ROW.

1-4

APPENDIX II LETTER FROM K. W. AMISH TO NYS PUBLIC SERVICE COMMISSION CONCERNING CASE 27605 AND THE ROLE OF HERBICIDES IN MANAGING VEGETATION ON ELECTRIC TRANSMISSION RIGHTS-OF-WAY

APPENDIX II ROCHESTER GAS AND ELECTRIC CORPORATION 89 EAST AVENUE, ROCHESTER, N.Y. 14649 KEITH W AMISH ANEACO0 546-2OO C7i6 CCUTrwC VICC PNCSIOCHT May 30, 1980 New York Public Service CommissiEon Agency Building #3 Governor Nelson A. Rockefeller Empire State Plaza Albany, New York 12223 Attention: Samuel R. Madison, Secretary Re: Case 27605 - The Role of Herbicides in Managing Vegetation on Electric Transmission Rights-of-Way.

Dear Commissioners:

Ih response to the New York Public Service Commission's order to show cause in the above-referenced case why the Commission should not direct Rochester Gas and Electric

.Corporation (the "Company") to institute a training program for herbicide applicators in species identification and the treatment of sensitive and critical areas located on or adjacent to transmission rights-of-way, the Company hereby submits that its present training program for herbicide applicators, described in detail below, ensures safe and effective selective application of herbicides in a manner designed to remove undesirable vegetation

  1. ihile preserving, as much as feasible, desirable vegetation.

Consequently, the Company respectfully urges the Commission to refrain from imposing the mandatory training program under consideration, a program which would be costly and unnecessary given the comprehensive nature of the Company's present practices in this regard.

The Company agrees that the proper training of herbicide applicators is essential for protecting environmental concerns.

For this reason the Company implemented a program in 1974 for the training of contractors performing ROW maintenance work. (All Company ROW maintenance work is performed by contractors.) The present training program consists of: (1) the utilization of selective clearing specifications; (2) the practice of holding pre-bid orientation meetings with contractors; (3) the field training of applicators; and (4) the field monitoring of maintenance activities.

The selective clearing specifications form the nucleus of the training program. They include all information necessary for the contractors to conduct an environmentally compatible ROW maintenance operation. The specifications include: (1) an explanation of the Company's selective clearing philosophy;

SHEET NO.

ROCHESTER GAS AND ELECTRIC CORP.

DATE May 30, 1980 2 To New York Public Service Commission (2) descriptions of acceptable chemical and mechanical treatment techniques; and (3) instruction concerning treatment of sensitive areas. A copy of the Company's Selective ROW Management Specifica tions is included for your perusal.

The Company's Selective Clearing Specifications are reviewed with the contractors on a page-by-page basis at the pre-bid orientation meetings to make it clear at the outset to all eligible bidders that the specifications are an integral part of the project. The District Manager in whose area the maintenance activities will be conducted, attends the orientation meetings to explain any specific concerns endemic to his District. After the specifications are thoroughly discussed, field visits to typical work areas and known sensitive areas are made with the contractors to further acquaint them with the specifications and any ROW constraints.

Upon the award of a contract to a specific con1Eractor, an Environmental Analyst from the Company's Environmental Engineering Department train the field crew(s) who will perform the maintenance operation. The Environmental Analysts also act as inspectors for all ROW maintenance activities. The Inspectors repeat the presenta tion given at the pre-bid orientation meeting and provide each crew with a copy of the Company's Selective Clearing specifications.

In addition, a training session in vegetation identification is conducted. This includes the Inspectors conducting a walking tour through a typical ROW area, explaining the differences between desirable and undesirable species. It has been the Company's experience that such training sessions have served to give herbicide applicators an adequate working knowledge of desirable/undesirable vegetation classifications as prescribed by the Company. It should be noted also that the crew foreman is experienced in herbicide application and has a responsibility to ensure that the Company's standards are followed. Throughout the training sessions the objective of saving as much desirable vegetation as possible is repeatedly emphasized.

Following training, the Company's Environmental Inspectors check to see whether the training has been effective. As part of their monitoring, Inspectors provide each crew member a copy of the herbicide formulation specifications and observe them mixing the formula to guarantee that the specifications are being adhered to. Upon completion of the mixing, the Inspectors observe the spray application techniques employed by the crew members. are If the Inspectors are of the opinion that improper techniques being used, they will demonstrate correct techniques. The crew members also are instructed on other relevant factors, such as volatility and drift of herbicides.

In the training program, sensitive areas such as orchards, vineyards, residences and streams, wherein spraying is to be 11-2

SHEET NO.

ROCHESTER GAS AND ELECTRIC CORP.

DATE May 30, 1980 3 ro New York Public Service Commission either limited or avoided, are identified. Buffer area dimensions are finalized as well as areas to be screened.

After the maintenance operation commences, the Company's are Environmental Inspectors oversee the operation until theythe satisfied that it is being conducted in accordance with standards for environmental care established by the Company. A notification system which has been developed keeps the contractor with each other on a and the Company's Inspectors in-contact to ensure daily basis. The Company's Inspectors also spot check that the operation is being carried out as specified.

In assessing the adequacy of the Company's training program, the Commission should bear in mind that the Company has not received any complaints from the Commission's Staff regarding If herbicide misuse since the program was initiated in 1974. in its Staff knows of any misuse of herbicides by the Company being franchise territory, the Company would certainly appreciate informed of such occurrences.

In conclusion, the Company submits to the Commission that program than the program imposition of a more elaborate training the Company presently adheres to in its training of herbicide applicators would not be cost effective given the that scope of the Company's present program. The Company believes its program with is sophisticated enough to provide herbicide applicators the safe and sufficient training to perform their objective: being the efficient removal of undesirable vegetation. This by the case, a more expansive program of.the type envisionedtime, effort Commission would result in a considerable amount of with little or no incre

.and money being expended by the Company For these reasons, the mental environmental benefit derived. refrain from Company respectfully requests that the Commission training requiring the Company to implement the contemplated program.

Very truly yours,

/< " "" h Keith W. Amish 11-3

Appendix III Selective Right-of-Way Management Specifications for Electric and Gas Rights-of-Way Rochester Gas and Electric Corporation January 1995 Pc:MGTI

Table of Contents 1.0 Forward - Selective Right-of-Way Management 2.0 Selective Management Procedures 2.1 Methods of Management 2.2 Methods of Disposal 2.3 Screens and Buffers 2.4 Special Conditions and Areas 3.0 Herbicide Treatment 3.1 General 3.2 Types and Formulations 3.3 Report Procedures for Herbicide Usage 3.4 Application of Herbicides 3.5 Notification 3.6 Special Considerations for Herbicide Application 4.0 Erosion Control 4.1 Streams and Wetlands 4.2 Gullies and Side Slopes 4.3 Seeding 5.0 Completion of Work 5.1 Final Report 5.2 RG&E Verification of Work Completed III-I

1. Forward Selective Right-of-Way Management Concept Selective right-of-way (ROW) management is designed to remove only those species capable of growing into the conductor or interfering with maintenance and inspection activities. Species will be removed on a case by case basis. For overhead electric lines this generally means removing primarily trees and leaving shrubs, forbs and grasses. For underground electric and gas lines, this generally means removing essentially all trees and shrubs, leaving primarily non-woody species such as forbs and grasses.

Any questions in regard to this part should be addressed to the System Forester.

All areas will be managed utilizing the selective concept, unless otherwise stated on the engineering drawings.

2. Selective Management Procedures 2.1 Methods of Management The following clearing methods are those acceptable to the Company. Each ROW section to be treated will be labeled with the appropriate method on the company engineering drawings. The prescribed method is to be strictly adhered to, with any variance to the prescribed method by the contractor to be considered a breach of the contract, unless prior approval has been granted by the System Forester, or his designee.

Note - Costs for each method of clearing and disposal will be presented in a per acre format. For example, Method HC,ST for 12 acres would cost $ per acre.

Selectively Hand Cut and Chemically Stump Treat - HC, ST To cut, no higher than 3" above ground level, non-compatible or, in some instances, compatible species or vegetation so noted for removal and to apply herbicide or herbicide mixture by a backpack, brush or other hand method (non-broadcast method) to individual cut stumps, completely saturating the stump and root collar area with herbicide or the cambium layer (the difference depends on the type of herbicide used). All distinguishable trees will be hand cut and treated.

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Selectively Hand Cut - HC To hand cut non-compatible or, in some cases, compatible tree species without any application of herbicide or herbicide mixture, usually with a chain saw.

Selective Basal Spray - BS To apply herbicide or herbicide mixture to the bottom 18-24 inches and root area of individual non-compatible species. This technique can be utilized year round except when snow depth covers the root collar. Oak species greater than 2 inches in diameter must be hand cut and stump treated.

Pretreatment - BS*

Same as basal spraying, except the trees are cut approximately five to seven days after treatment, or as soon as the first signs of brownout appear. Stumps are cut as close to ground line and should not exceed 3 inches.

Selective Foliar Spray - FS To treat by herbicide mixture the leaves and stems on non-compatible species under 8 feet in height growing in concentrated areas along the right-of-way. Selective foliar spray shall be done by backpack, or any other device which exhibits good control of spray on concentrated areas of vegetation.

Hydro-ax/Brush Hog/Kershaw - HA To remove by Hydro-ax, brush hog, or Kershaw, non-compatible and/or compatible vegetation along the right-of-way. Stump height is not to exceed 3 inches. No debris is to be left on active farmland.

Mechanical cutting methods are most suited to sensitive and special consideration areas such as chemical exclusion sites and seasonally dry wetlands with relatively pure stands of young undesirable species. The terrain should be flat with no gullies or rocks.

Side Trim - SIT To remove by cutting or spraying limbs or trees along the furthest limits of the right-of-way edge.

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Selective Trim - SET To cut or top non-compatible as weil as compatible species so as not to destroy the tree and to retain as much of the tree as possible without endangering the conductors.

Side and selective trimming near electric utility lines is performed only by qualified personnel. Personnel are trained in pruning techniques and have a clear understanding of the safety and line clearing requirements as directed by OSHA and ANSI Z 133.1-1994 and CFR 1910.269.

All limbs are to be cut at nodes as close as possible to the bark branch collar (drop crotch, or natural target pruning).

Topping, removing the branch collar, leaving stubs and painting cut with wound dressing is not recommended.

No Treatment - NT No physical alterations are to take place to this area.

Note: BS* is variations on treatment "BS" 2.2 Methods of Disposal Chipping - CH To be primarily used in areas where slash cannot remain (e.g.,

wetlands, road crossings, stream crossings, and residential areas).

Trees up to 8 inches in diameter may be chipped. Chips may be evenly applied to the right-of-way to a thickness of 2" to 3",

hauled off site or piled for later use.

Lop and Drop - LD Woody material is hand cut with a chain saw left to lie where it drops. All trees greater than 3 inches in diameter will be limbed flush to the trunk. No wood or brush is to be left on active farmland.

Hand Pile or Mechanically Pile and Crush - PC Slash resulting from tree removals (limbs > 3" diameter) shall be moved by hand or machine and piled along the edge of the right of-way and crushed. A dozer is used to crush the pile to reduce the volume. Small volumes of slash can be hand piled without mechanical crushing.

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Brush piles shall not exceed 40' X 40' in length nor be higher than eye level. Natural depressions and gullies should be chosen on the down-hill slope side of the right-of-way wherever possible to help prevent soil erosion.

Windrowing - WR Woody material that has been delimbed will be carried by hand or pushed (depending on the situation) with a bulldozer to the either side of the cleared right-of-way.

Note: All wild cherry, cut or sprayed in areas where livestock may be grazing shall be removed from the site in order to prevent poisoning of the livestock.

2.3 Screens and Buffers 2.3.1 Screens Screens will be maintained to the fullest extent possible at all major road crossings if deemed appropriate. For overhead electric lines this would result in maintaining a minimum of a 20 foot deep screen. A larger (deeper) distance may be requested by the Environmental Analyst. Small, undesirable trees will be retained, while large undesirables can also be retained, provided trimming does not produce an unnatural appearing situation.

For underground electric and gas lines, a minimum of a 20 foot deep screen would also be maintained if deemed appropriate. Trees and shrubs, not normally retained, would be allowed to remain.

2.3.2 Buffer Zones A buffer zone will be an interim area between the work area and an environmentally sensitive area in which extra precautions would be taken to ensure the environmental integrity of that system.

All streams, wells, springs, livestock, watering areas, other bodies of water, and croplands as well as any sensitive or unique wildlife habitats or wetlands will be programmed for a buffer zone.

The width and depth would be based on a site by site analysis to be detailed on the engineering drawings.

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2.4 Special Conditions and Areas 2.4.1 Topographic Conditions Where the conductor height above ground and/or the slope of the ground on the right-of-way allows mature trees to remain harmless to the conductors, all tree growth will be left except for needed access. This will be based on the emergency short term loading as indicated on the engineering drawings. This will not apply to gas or underground electric lines where the normal selective techniques would be fully employed.

2.4.2 Steep Side Slopes Steep side slopes narrow the right-of-way on the down slope side where the designed minimum conductor clearances are magnified by the declining slope. The amount of narrowing will be determined in the field by the System Forester according to the anticipated mature forest heights, degree of slope, and the designed minimum conductor clearances to ground. The up slope area would be treated in the normal fashion. This will not apply to gas or underground electric lines. In these situations the ROW width would be constant.

2.4.3 Danger Trees Trees along the edge of right-of-way and exceptionally large trees on the right-of-way and those in topographically specialized area that present a significant reliability risk are considered danger trees. These trees are identified and marked by the System Forester or Environmental Analyst as soon as possible after initial clearing is completed. Danger trees are also identified during subsequent maintenance cycles through detailed line inventories, patrols and aerial inspections. Danger trees are trimmed or removed following notification and negotiations with the property owner. Cutting and disposal of danger trees shall be the same as previously specified.

2.4.4 Miscellaneous (a) Flood areas - All logs and brush cut in low-lying area shall be moved to high ground above probable flood levels and piled as specified previously.

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(b) Retention of Certain Undesirable Trees - Certain instances may require leaving normally undesirable trees due to aesthetic considerations, landowner requests or current land use situations. These will be marked on the engineering drawings accordingly.

3. Herbicide Treatment 3.1 General All herbicide applications, formulations, equipment and application must abide by all federal, state and local laws pertaining to herbicides and be kept current. The contractor will be responsible for guaranteeing a 99% kill on all spray operations.

This will be field determined by the contractor and the System Forester, or Environmental Analyst within one year.

3.2 Types and Formulations The following herbicides are the only ones currently acceptable to the Company as ROW herbicides:

High Volume Foliar Spray Mixtures

1. Krenite S* 3 gallons in 98 gallons of water
2. Garlon 3A and Tordon 101 - 1/2 gallon of each in 99 gallons of water with suitable surfactant and Nalco-Trol.
3. Garlon 4 - 2 quarts mixed with 2 quarts of Tordon 101 in 99 gallons of water with suitable surfactant and Nalco-Trol.

Low Volume Foliar Spray Mixtures

1. Arsenal and Accord - 3/4% Arsenal, 3% Accord, 1/2%

surfactant and 95.5% water.

Cut Stump Spray

1. Garlon 3A - apply as required to the cambium layer of the cut stump mixed 1:1 with water or undiluted.

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2. Garlon 4 - 20 to 30 gallons of Garlon 4 in enough oil to make 100 gallons of mix.
3. Garlon 4 and Access - 12.5% Garlon 4, 12.5% Access and oil.
4. Compadre - Ready to use product.
5. Accord - 50% Accord, and proper mixture of water and antifreeze.

Basal

1. Garlon 4 - Conventional Treatment, 1 to 5 of Garlon 4 in enough oil to make 100 gallons of mix.
2. Garlon 4 - Low Volume, 20 to 30 gallons of Garlon 4 in enough oil to make 100 gallons of mix.
3. Garlon 4 and Access - 12.5% Garlon 4, 12.5% Access and oil.

The contractor will be responsible for proper equipment type and proper operating condition of, as well as proper spray pressures and agitation method to be utilized for spray operations.

All chemical solutions will be applied through a hand-held nozzle by persons walking the ROW. The source of material may be either power-driven equipment or knapsack spray tanks. Spray nozzles will be adequate to produce a coarse spray of large droplets at the lowest pressure necessary to provide adequate coverage.

When withdrawing water from natural water bodies or hydrants, the contractor shall employ a nurse truck or tank truck equipped with an anti-back syphoning devices to prevent any potential contamination from occurring in these areas.

No spraying will be conducted when snow or ice is 2 inches or more in depth. Vegetation and/or stumps treated one hour or less prior to rain will be sprayed again but not until one hour after runoff has stopped. All stumps will be treated within 24-hours of cutting when using Method HC, ST. All ash species will be cut and stump treated when exceeding ten feet in height (when using Method BS.)

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When selective stem foliar is used on a root suckering species area (e.g., Quaking Aspen and Black Locust), the soil around each stem will also be saturated to ensure root kill.

The contractor will be responsible for any damage resulting from any chemical application or contamination of water bodies.

3.3 Report procedures for Herbicide Usage The contractor shall keep records of chemical application and furnish the Company with dated daily reports of chemical application showing the name or number of the line and all other data requested by the New York State Department of Environmental Conservation. Additional data includes formulation, rate, amount of mix used, area treated (and location) and any additional comments. These daily reports must be completed and submitted at the end of each week.

3.4 Application of Herbicides Application of herbicides will be conducted under the super vision of the contractor's certified pesticide applicator.

Application techniques are to be employed per the direction of 2.1, Methods of Management.

3.5 Notification Notification of landowners with a structure adjacent to fee-owned properties or where an easement is held is required when the treatment will be within 100 feet of the building. This notification shall take place at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> but not more than one week prior to treatment.

The Company's notification will include pertinent label information as required by the New York State Department of Environmental Conservation. The method of notification to be employed will consist of one or all of the following:

(1) personnel contact, (2) door knob hanger or (3) mailing. In addition, areas to be sprayed shall be posted if within 100, of a dwelling, multiple dwelling, public building or public park.

Visual notification markers shall be 12 x 12 inches square, 12 inches above ground and at 150' intervals clearly identifying the treatment site.

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A record of all notification letters delivered shall be kept for a minimum of 3 years by Rochester Gas and Electric Corp. The record shall consist of the date, time, manner of delivery, place of delivery, and if delivered in person the name of that person.

3.6 Special Considerations for Herbicide Application Herbicide spraying generally will not be conducted in residential areas, unique wildlife habitat areas, (to be determined by the System Forester or the Environmental Analyst), landowner objection areas, croplands, orchards, streams or other water bodies. Additional areas may be added to the exempt list as determined by the Company. All non-spray areas will be detailed on the Company engineering drawings.

The following areas shall not be treated by any herbicide application methods.

1. Within a minimum of 25 feet of a stream, lake, pond or other water body or 100 feet of a designated wetland.
2. Within 100 feet of active residences or dwellings (250 feet for foliar spray applications), without required notification.
3. Within 25 feet of active croplands, orchards, etc.

(50 - 200 feet for foliar spray, depending on crop type).

4. Within 25 feet of parks, golf courses, etc., (100 feet for foliar spray) without required notification.
5. Within a minimum of 100 feet from any known active spring, well, or stock watering area.
4. Erosion Control 4.1 Streams and Wetlands Work in or adjacent to streams and wetlands will be conducted in accordance with NYS ECL Article 24 for Wetlands and Article 15 for Protected Streams and Army Corps 404 permits regarding discharge, soil erosion and chemical mixing, handling and storage.

III-10

All streams and water courses are to be kept open and free of all debris at all times. Every effort will be made to keep debris from falling into open waters. All debris that falls into water courses must be removed at the time of cutting.

All ruts and other mechanical disturbance caused by the contractor to streams, approaches, or seeps shall be topsoiled, graded, seeded, and mulched and be in as good as or better condition than originally found before work began. This work must be completed within eight days of initial disturbance.

4.2 Gullies and Side Slopes These are areas where brush can be piled and crushed (or just piled) provided these areas are not normally having water flowing through them for the majority of the year.

4.3 Seeding of access roads and ROW's All access roads and any areas where the soil has been denuded will be reseeded both for any maintenance and capital work.

Seeding will be done either by cyclone spreader or hydroseeder within 8 days after work is completed in any one area.

Seed mixtures will be determined by the Forester or Environmental Analyst and will be in accordance with the U.S.D.A.

Soil Conservation Service specifications for seeding.

Consideration shall be given to soil conditions, type and slope.

Currently acceptable seed mixtures are:

Formula #1. For use March through August. 16 lbs. spring oats (1/2 bu.) + 20 lbs. perennial ryegrass/acre.

Formula #2. For use September through February. 30 lbs. winter wheat (1/2 bu.) + 20 lbs. perennial ryegrass/acre.

Formula #3. For use in wet, swampy areas, 8 lbs. birdsfoot trefoil

+ 10 lbs. redtop/acre.

III-11

5. Completion of Work 5.1 Final Report by Contractor Upon completion of work for a particular job/ROW section the Contractor will provide (unless otherwise stated) a report listing the final cost/acre/clearing or disposal method.

Herbicide usage information (see 3. Herbicide Treatment) shall be tallied from daily reports and reported.

5.2 RG&E Verification of Work Completed Upon notice by the contractor that the work has been completed (which includes any clean-up or restoration work), the System Forester will review and approve the job before final payments are made to the contractor. The verification of completion of the job shall be sent to the Purchasing Department with copies to the respective gas/electric maintenance department.

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Appendix IV KEY TO VEGETATION NAME ABBREVIATION TREES D - Desirable species, 34.5 kV and 115 kV circuits U - Undesirable species, 34.5 kV and 115 kV circuits U/D - May be undesirable on 34.5 kV circuits and desirable on 115 kV circuits DESIGNATION COMMON NAME BOTANICAL NAME ABBA U Balsam Fir Abies balsamea U Boxelder Acer negundo ACNE Acer pensylvanicum ACPE U/D Striped Maple U Norway Maple Acer platanoides ACPL Acer rubrum ACRU U Red Maple U Sugar Maple Acer saccharum ACSA Acer saccharinum ACSR U Silver Maple U Ailanthus Ailanthus altissima AIAL Amelanchier spp.

AMSP U/D Serviceberry BEAL U Yellow Birch Betula alleghaniensis U Sweet Birch Betula lenta BELE U White Birch Betula papyrifera BEPA Betula populifolia BEPO U Gray Birch U/D American Chestnut Castanea dentata CADE Carpinus caroliniana CACA U/D American Hornbeam U Bitternut Hickory Carva cordiformis CACO Carva glabra CAGL U Pignut Hickory U Shagbark Hickory Carva ovata CAOV Cornus alternifolia COAL D Alternate-leaved Dogwood COFL U/D Flowering Dogwood Cornus florida U/D Hawthorn Crataecrus spp.

CRSP arandifolia Faus FAGR U Beech U White Ash Fraxinus americana FRAM Fraxinus pennsylvanica FRPE U Green Ash U Honeylocust Gleditsia tricanthos GLTR JUCI U Butternut JuQlans cinerea U Black Walnut Juglans nfig_

JUNI Juniperus virginiana JUVI U/D Red Cedar LALA U American Larch Larix laricina U Tulip Poplar Liriodendon tulipifera LITU Maclura pomifera MAPO U/D Osage-orange U/D Apple Malus spp.

MASP Ostrya virciniana OSVI U/D American Hophornbeam U Norway Spruce Picea abies PIAB Picea glauca PIGL U White Spruce U Red Pine Pinus resinosa PIRE Pinus ricida PIRI U Pitch Pine U Red Spruce Picea rubens PIRU Pinus strobus PIST U White Pine U Scotch Pine Pinus sylvestris PISY Pinus virginiana PIVI U/D Scrub Pine PLOC U Sycamore Platanus occidentalis U Cottonwood Populus deltoides PODE Populus grandidentata POGR U Bigtooth Aspen U Quaking Aspen Populus tremuloides POTR Prunus pensylvanica PRPE U/D Pin Cherry Black Cherry Prunus serotina PRSE U U Douglasfir Pseudotsuga menziesii PSME

IV-1 KEY TO VEGETATION NAME ABBREVIATION TREES DESIGNATION COMMON NAME BOTANICAL NAME QUAL U White Oak Ouercus alba U/D Scrub Oak Ouercus ilicifolia QUIL Quercus prinus QUPR U Chestnut Oak U Red Oak Ouercus rubra QURU Rhamnus cathartica RHCA D Buckthorn U Black Locust Robinia pseudoacacia ROPS Sassafras albidum SAAL U White Sassafras U Willow Salix spp.

SASP Thula occidentalis THOC U/D White Cedar U Basswood Tilia americana TIAM Tsuga canadensis TSCA U Hemlock U American Elm Ulmus americana ULAM KEY TO VEGETATION NAME ABBREVIATION SHRUBS D - Desirable species, 34.5 kV and 115 kV circuits U - Undesirable species, 35.5 kV and 115 kV cirucits U/D - May be undesirable on 34.5 kV circuits or desirable on 115 kV circuits DESIGNATION COMMON NAME BOTANICAL NAME ACSP U/D Mountain Maple Acer spicatum D Speckled Alder Alnus rugosa ALRU Alnus spp.

ALSP D Alder D Black Chokeberry Aronia melanocarpa ARME Berberis spp.

BESP D Barberry D New Jersey Tea Ceanothus americanus CEAM Cephalanthus occidentalis CEOC D Buttonbush D Climbing Bittersweet Celastrus scandens CESC Cornus amomum COAM D Silky Dogwood D Sweet Fern Comptonia peregrina COPE Corylus spp.

COPP U/D Hazelnut D Gray Dogwood Cornus racemosa CORA Cornus sericea COSE D Red Osier Dogwood D Dogwood Cornus spp.

COSP Gaylussacia spp.

GASP D Huckleberry U/D Witchhazel Hammamelis virginiana HAVI Ilex verticillata ILVE D Winterberry Common Juniper Juniperus communis JUCO D D Mountain Laurel Kalmia latifolia KALA Lindera benzoin LIBE D Spicebush Privet Licnustrum spp.

LISP D D Honeysuckle Lonicera spp.

LOSP Nemopanthus mucronata NEMU D Mountain Holly U/D Choke Cherry Prunus virQiniana PRVI Rhus glabra RHGL U/D Smooth Sumac U Pinxter Flower Rhododendron periclymenoides RHPE Rhus typhina RHTY U/D Staghorn Sumac D Raspberry gibes spp.

RISP Rosa multiflora ROMU D Multiflora Rose

IV-2 KEY TO VEGETATION NAME ABBREVIATIONS SHRUBS DESIGNATION COMMON NAME BOTANICAL NAME ROSP D Rose Rosa spp.

RUSP D Blackberry Rubus spp.

RUSP D Dewberry Rubus spp.

SACA D Elderberry Sambucus canadensis SASP U/D Pussy Willow Salix spp.

SPSP D Spirea Spiraea spp.

TACA D Canadian Yew Taxus canadensis TORA D Poison Ivy Toxicodendron radicans TOVE U/D Poison Sumac Toxicodendron vernix VASP U Blueberry Vaccinium spp.

VIAC D Maple Leaved Viburnum Viburnum acerifolium VIAL D Hobblebush Viburnum alnifolium VICA D Wild Raisin Viburnum cassinoides VIDE D Arrowwood Viburnum dentatum VILE D Nannyberry Viburnum lentago VIPR D Blackhaw Viburnum Viburnum prunifolium VISP D Grape Vitis spp.

VITR D Highbush Cranberry Viburnum trilobum ZAAM U/D Northern Prickley Ash Zanthoxylum americanum