September 30, 2011 - documents.dps.ny.gov

September 30, 2011

i NYSEG RG&E ROWMGMPLAN 09-30-2011

TABLE OF CONTENTS

1. General. . . . . . . . . . .. . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . 1 A. Introduction. . . . . . . . . . .. . . . . . .. . . . . . . . . . . . . . . . . . . . 1 B. Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2. Description of NYSEG and RG&E . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. Service Territory . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 B. ROW Management Structure & Organization for Planning and Operations . . . . 3 C. Key Positions in Vegetation Management Program and General Functions . . . . 3 D. Description of the Transmission Right-of-Way System. . . . . . . . . . . . . . . 5

1. System Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2. Components of the Transmission System . . . . . . . . . . . . . . . . . . . 5 3. Right-of-Way Width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

E. Transmission Right-of-Way Ownership . . . . . . . . . . . . . . . . . . . . . . . 6 1. Vegetation Management Restrictions. . . . . . . . . . . . . . . . . . . . . . 7 2. Replanting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 3. Work Notification Procedures . . . . . . . . . . . . . . . . . . . . . . . . . 7

3. History of Right-Of-Way Management Policies and Practices. . . . . . . . . . . 8 A. Past Practices and Policies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 B. Present Practices and Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 C. Wire Zone / Border Zone Concept of Integrated Vegetation Management. . . . . 11

4. Goals of The Right-Of-Way Management Plan. . . . . . . . . . . . . . . . . . . 13

5. Transmission Right-Of-Way Vegetation Management Procedures . . . . . . . . 15 A. The Wire Zone / Border Zone Method and Clearance . . . . . . . . . . . . . . . 15

1. The Wire Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 2. The Border Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 3. Mitigation Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 4. Undesirable Tall Growing Species. . . . . . . . . . . . . . . . . . . . . . . 18 5. Tall Shrubs and Small Trees . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6. Woody Shrubs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

B. Selection of Vegetation Management Techniques. . . . . . . . . . . . . . . . 20 C. Definition of Vegetation Densities . . . . . . . . . . . . . . . . . . . . . . . . 20 D. Description of Vegetation Management Techniques and Conditions of Use. . . 21

1. Conventional Stem Foliar Technique. . . . . . . . . . . . . . . . . . . . . 21 2. Low Volume Foliar Technique. . . . . . . . . . . . . . . . . . . . . . . . 22 3. Basal Technique . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 4. Cutting and Stump Treatment Technique. . . . . . . . . . . . . . . . . . . 24

ii NYSEG RG&E ROWMGMPLAN 09-30-2011

5. Cutting/Pruning Technique. . . . . . . . . . . . . . . . . . . . . . . . . . . 25 6. Mechanical Mowing Technique . . . . . . . . . . . . . . . . . . . . . . . . 25

E. Hazard Tree Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 1. Hazard Tree Identification. . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 2. Hazard Tree Inspection Schedule. . . . . . . . . . . . . . . . . . . . . . . . 27 3. Hazard Tree Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 4. Budgeting for Hazard Tree Removal . . . . . . . . . . . . . . . . . . . . . . 28

6. Planning the Annual Vegetation Management Program . . . . . . . . . . . . . . 28 A. Maintenance Cycle and Relationship to Goals . . . . . . . . . . . . . . . . . . 28 B. Determination of Rights-of-Way To Be Treated . . . . . . . . . . . . . . . . . 28

1. Rights-of-Way Treatment Determinations Based on Electrical Clearance Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . 29

2. Determination of Right-of-Way To Be Treated Based on Maintenance Cycle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

C. Vegetation Line Patrols. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 1. Scheduled Patrols . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 2. Emergency Patrols. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

D. Detailed Right-of-Way Inventory and Design Criteria . . . . . . . . . . . . . . 32 1. VMS Inventory. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 2. VMS Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

E. Budget Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 F. Program Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

7. Implementing the Annual Vegetation Management Program . . . . . . . . . . . 33 A. Selection of a Contractor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 B. Program Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

1. Scheduling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 2. Specific Instructions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 3. Work Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 4. Monitoring of Work in Progress . . . . . . . . . . . . . . . . . . . . . . . 34 5. Landowner Inquiries and Concerns. . . . . . . . . . . . . . . . . . . . . . 34

C. Quality Control and Guarantee . . . . . . . . . . . . . . . . . . . . . . . . . . 34 D. Record Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

8. Regulatory Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 A. U.S. Environmental Protection Agency . . . . . . . . . . . . . . . . . . . . . 35 B. New York State Department of Environmental Conservation . . . . . . . . . . 35 C. New York State Public Service Commission. . . . . . . . . . . . . . . . . . . 36 D. Pennsylvania Department of Agriculture, Bureau of Plant Industry. . . . . . . . 37 E. Pennsylvania Department of Environmental Resources . . . . . . . . . . . . . 37 F. Pennsylvania Game Commission . . . . . . . . . . . . . . . . . . . . . . . . . 37 G. New York City Department of Environmental Protection, Bureau of

Water Supply (DEP). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 H. Northeast Power Coordinating Council (NPCC) . . . . . . . . . . . . . . . . . 38 I. North American Electric Reliability Corporation (NERC) . . . . . . . . . . . . 38

iii NYSEG RG&E ROWMGMPLAN 09-30-2011

9. General Budgeting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

10. Plan Evaluation, Review and Updating . . . . . . . . . . . . . . . . . . . . . . . 39

11. Present and Anticipated Research Activities. . . . . . . . . . . . . . . . . . . . 40

APPENDIX A Detailed Specifications for Transmission Right-of-Way Vegetation Maintenance

APPENDIX B Component Lines of the Transmission System

APPENDIX C Quality Assurance Plan

APPENDIX D Service Area & Transmission System Maps

APPENDIX E ROW Maintenance Worker Training and Protection of Sensitive Areas

APPENDIX F Special Plan Conditions Which Apply to the Adirondack Park

APPENDIX G NERC Vegetation Management Standard FAC-003-1

APPENDIX H Outage Report

APPENDIX I NPCC-CGS-001: Reporting of Vegetation Contacts Within 48 Hours

NYSEG RG&E ROWMGMPLAN 09-30-2011 1

1. General

A. Introduction

This plan is organized to meet the specific requirements of the New York Codes, Rules and Regulations, Title 16, Chapter I, Subchapter F, Part 84 requiring the development of a long-range right-of-way management plan for electric transmission systems. In accordance with these requirements, NYSEG and RG&E submitted separate plans to the Public Service Commission (PSC) in March of 1981 for their transmission systems.

In April of 1983 the PSC ordered the approval for the portion of the NYSEG system outside of the Adirondack Park. At the same time the PSC Staff was directed to prepare a draft Programmatic Environmental Impact Statement on this plan as it related to the Adirondack Park. On July 20, 1988 the PSC issued an order in Case 27605, approving the plan within the Adirondack Park with conditions. These conditions are contained in Appendix F, Special Plan Conditions Which Apply Within the Adirondack Park.

Minor revision to the plans were made in 1994/5 when the then new low-volume selective stem-foliar technique was added as a treatment method. In 2006 a major NYSEG revision incorporated the (1) wire zone/border zone concept and (2) provisions of the PSC Order Requiring Enhanced Transmission Right-Of-Way Management Practices By Electric Utilities effective June 20, 2005. This brought the plan into compliance with the NERC Vegetation Management Standard, FAC-003-1. FAC-003-1 is found in Appendix G.

This current revision is submitted for a number of purposes: the merging of the NYSEG and RG&E plans, updating the organizational structure and the line mileage/acreage statistics, inclusion of RG&E, modifying the aerial patrol schedule, adding a definitions section, updating verbiage, adding a replanting section and other minor changes.

The plan is intended to be a working guide for Company personnel who work on various aspects of the transmission vegetation management program. It sets forth the basic procedures and practices that are used in planning, implementing, and controlling right-of-way vegetation management program on approximately 5,343 miles of transmission line rights-of-way in New York and Pennsylvania.

The intention of the plan remains that it be long-range in nature. However, changes and revisions will be made as necessary.


B. Definitions

Bulk Transmission Lines Company transmission lines operating at 230kV or 345kV.

Border Zone The outer portion of the right-of-way floor, extending from the outside edge of the wire zone to the edge of the specified right-of-way clearing width.

Company NYSEG and RG&E

Hazard Trees A structurally unsound tree that could strike an electric supply line. See Section 5.E.

Integrated Vegetation Management (IVM)

A vegetation management system employing several control methods based on effectiveness, environmental impact, site characteristics, safety, security, and economics to protect the reliability of the transmission system.

Minimum Clearance Achieved At the Time of Maintenance

The radial space around the conductor that creates a wire security zone under all rated operating conditions. This distance varies with voltage. Woody species capable of growing tall enough to intrude into this zone must be removed at the time vegetation management work is performed. Section 5.A. 1 and 2 for possible exceptions.

Minimum Clearance Zone

The radial space around the conductor into which the vegetation is not allowed to grow. This distance is to be maintained under all rated operating conditions and varies with voltage. Any plant within the specified right-of-way clearing width shall be removed if its mature height would fall or otherwise intrude into this distance.

Pruning The cutting or removal of tree branches to provide specified clearance distance between vegetation and the conductors.

Removal The felling or killing of undesirable vegetation.

ROW Right-of-way

Selective Treatment The removal, by herbicide treatment or cutting, of vegetation designated for removal and the retention of vegetation designated to be preserved.

Sensitive Area Areas on the ROW where legal or environmental impacts/concerns require compromises to the general treatment approach.

VMS Vegetation Management System

Wire Zone The floor of the ROW that is both underneath the conductors and a specified outer distance measured horizontally from the outermost conductors. The distance varies with voltage.


2. Description of NYSEG and RG&E

A. Service Territory

New York State Electric and Gas Corporation (NYSEG) is engaged primarily in the transmission, distribution and sale of electricity and natural gas in an area of approximately 17,000 square miles in the south central, eastern, and western parts of New York State. This area represents approximately 40% of the land area of New York State. The NYSEG service area and its 13 divisions are shown on the map in Appendix D.

Rochester Gas and Electric Corporation (RG&E) is engaged primarily in the transmission, distribution and sale of electricity and natural gas in an area of 2,700 square miles in the western part of New York State. The area represents approximately 6% of the land area of New York State. The RG&E service area is shown on the map in Appendix D.

The NYSEG service territory covers all or part of 43 counties which includes 13 cities, 154 incorporated villages and numerous rural areas. NYSEG serves nearly 873,000 electric customers and 259,000 gas customers.

The RG&E service territory covers all or part of 43 counties which includes 13 cities, 154 incorporated villages and numerous rural areas. RG&E serves nearly 362,000 electric customers and 299,000 gas customers

B. ROW Management Structure & Organization for Planning and Operations

The management structure for the Company right-of-way vegetation management program is shown on the organization chart on the following page, as of 10/01/2010. The overall vegetation management responsibilities reside within Engineering and Asset Management. Personnel in this department establish the Company-wide policies, procedures, techniques and co-ordination for the program. It also provides most of the operational implementation of the program, with foresters located in its operating divisions providing guidance and oversight.

C. Key Positions in Vegetation Management Program and General Functions

Program Manager- Vegetation Management: Responsible for general administration and coordination of the program, including procedures and techniques to implement the program.

Manager Vegetation Management Transmission: Reports to the Program Manager- Vegetation Management and is responsible for compliance with federal and state regulations. Develops budgets and provides oversight of vegetation management spending in accordance with budget allocation. Develops specifications, standards, work procedures, and materials for the program.


Conducts random quality assurance and control audits across the transmission system. Responsible for addressing customer issues to minimize PSC complaints and improve customer satisfaction.

Manager Vegetation Management Distribution-NY: Reports to the Program Manager- Vegetation Management and directly supervises division forestry staff to assure that the vegetation management program is implemented effectively and prudently. Analyst: reports to the Program Manager- Vegetation Management. Working with the Mangers of Vegetation Management prepares reports and monitors expenditures.

Lead Analyst Vegetation Management: reports to the Manager Vegetation Management Distribution-NY. These foresters are responsible for the implementation of the program in the divisions. Performs planning, monitors budgets, initiates work, provides quality assurance, crew oversight, and customer conflict resolution for Company transmission lines within NYS and in some cases, PA.

VP-Asset Management &

Planning

Director-Maintenance

Delivery

Program Manger- Vegetation

Management

Manger Vegetation

Management Transmission

Manger Vegetation

Management Distribution-NY

Analyst

Lead Analyst Vegetation

Management (Company Foresters)


D. Description of the Transmission Right-of-Way System

1. System Location

The NYSEG transmission system is within multiple regions of New York State while the RG&E system is located in the western part of New York State. Overview maps can be found in Appendix D.

2. Components of the Transmission System

The NYSEG system is made up of approximately 4443 miles of transmission with voltages ranging from 34.5 kV to 345 kV.

NYSEG Transmission Pole Line Mileage by Voltage

Voltage Mileage <69kV 2253 69kV 9

115kV 1400

230kV 230 345kV 551

Total

4443

NYSEG Transmission Pole Line Mileage by Division

Division Mileage Auburn 155 Binghamton 512 Brewster 213 Elmira 561 Geneva 285 Hornell 500 Ithaca 301 Lancaster 480 Liberty 302 Mechanicville 242 Oneonta 565 Plattsburgh 327

Total

4443


The RG&E system is made up of approximately 900 miles of 34.5 kV and 345 kV transmission.

Transmission Pole Line Mileage by Voltage

Voltage Mileage 34.5kV 660 115kV 240

Total

900

A general listing of the two transmission systems can be found in Appendix B. This schedule, by division, lists the line number, origin and termination point, operating voltage, type of supporting structure, and length in miles, acreage and year last treated of each transmission line.

3. Right-of-Way Width

Widths of rights-of-way generally vary according to the voltage and type of supporting structure. Normal right-of-way widths for the various voltages on the NYSEG and RG&E systems are listed below. A range of widths is given to account for variations in the types of supporting structures, e.g. single pole v. H-frame.

Typical Transmission ROW Widths

Voltage

<115kV 115kV 230kV 345kV NYSEG Widths

50 - 100

75 - 150

150

150 - 180

RG&E Widths

40 - 100

50

150

--- ---

Although the right-of-way widths usually fall within the above ranges at the stated voltages, there are situations in which the right-of-way width will vary on a given line segment. For example, the right-of-way width may be greater than normal for clearance when a span is extra-long. Conversely, the right-of-way width could be less than normal where the line is routed through a sensitive area requiring special construction design and right-of-way clearing. These locations must also receive special consideration for right-of-way management.

E. Transmission Right-of-Way Ownership

The usual practice is to acquire property rights to erect, operate, and maintain the transmission system through the acquisition of easements from the property owners. These easements leave the ownership of the land in the hands of the owner, so that they can continue to use the land, subject to certain restrictions that


insure the owner s and the public s safety, while also permitting the operation and maintenance of the transmission facility. Easement rights include the right to initially clear vegetation from the right-of-way to facilitate construction and to subsequently perform operations that will control vegetation to provide for the safe and reliable operation of the transmission line.

A small percentage of rights-of-way are owned in fee or, in the case of rights-of-way across public lands, rights are secured by way of permits. These permits generally provide the same rights as those in an easement however there are sometimes special conditions and may include an annual fee paid to the entity issuing the permit.

1. Vegetation Management Restrictions

Any landowner or land user restrictions that may impact right-of-way vegetation management are incorporated at the time of initial right-of-way conveyance into the legal document and/or agreement, which grants the right to erect, operate, and maintain its facilities. These restrictions are incorporated into all work specifications to assure compliance. Landowner or land user requests for modification of vegetation management practices are analyzed and considered. The analysis considers such factors as regulatory requirements, economics, environmental impact, safety, operational feasibility, and practicality of the request.

2. Replanting

Replanting of vegetation may be an option during certain negotiations with property owners. These negotiations include (1) when seeking new or additional clearing rights or (2) if the vegetation work exceeds existing rights, replanting may be an option in the damage claim settlement. The funding of replanting will be determined by business needs and shall not adversely affect the annual budget.

Upon request, the Company may cooperate with municipal planting programs that do not encumber its transmission right-of ways. These requests are subject to budgetary considerations and shall not adversely affect the annual budget.

3. Work Notification Procedures

At a minimum contacts are made to notify the landowner of planned vegetation management operations in the following situations:

When easement restrictions require prior notification.

When the work effort involves lands that are off the right-of-way, either for access or for tree removals.

When law requires notification pursuant to herbicide applications.


3. History of Right-Of-Way Management Policies and Practices

A. Past Practices and Policies

The primary goal of those responsible for transmission vegetation maintenance has not changed over the years; it is to maintain the system free from tree-caused outages. Prior to the advent of chemical methods of vegetation control and the development of reliable chainsaws, the work was performed with inexpensive hand labor utilizing axes, brush hooks, and hand saws. A limited amount of vegetation maintenance work was accomplished by grubbing the rights-of-way with bulldozers. In these early years, the transmission system was small, not only in length, but also in width due to the lower voltages then in use.

Even though labor was cheap and the system small, these methods of control were incapable of producing long-term effectiveness, due to the ability of hardwood species to resprout from their existing root systems. Following cutting or grubbing, the right-of-way vegetation naturally responded to this disturbance by resprouting vigorously and in great numbers, from both cut stumps and roots. This resprouted vegetation was capable of accelerated growth, because it was supported by an established root system.

Therefore the right-of-way management program during this era amounted to a labor-intensive, never-ending battle against resurgent brush. Long-term goals of vegetation stabilization were not an option, since no method existed that could prevent resprouting of undesirable hardwood species.

Soon after World War II, herbicides came in to use as a tool for vegetation management on utility rights-of-way. It is not known exactly when herbicides were first used on the Company system, however right-of-way easements dating back to 1952 make mention of the use of chemicals for removing vegetation. It can be assumed from this that herbicides had been tested and found to be effective during prior years. Herbicides provided a means by which vegetation could be managed instead of simply controlled, as is the case with cutting. Herbicides were capable of root-killing vegetation, allowing densities to be reduced, and cycle lengths between treatments to be increased. Herbicides also reduced labor costs. The first applications were probably non-selective foliar-applied broadcast applications. During the 1950 s, ester formulations of 2,4,-D and 2,4,5,-T were developed that made more selective basal applications possible. The field of vegetation management began to grow at this time, as new methods, materials, and philosophies developed.

Selective vegetation management practices were introduced to the Company system during the 1950 s. Selective vegetation management, as it applies to electric transmission rights-of-way, is the selective removal of undesirable species (this was defined as any species that was capable of growing up to the conductors), and the retention of low-growing or desirable species (this was


defined as any species whose mature height was incapable of reaching the conductors). Theoretically, the desirable species would eventually form a dense and stable plant community that would prevent the undesirable species from invading the right-of-way through competition for sunlight, moisture, and nutrients.

Herbicides are basic to this practice because undesirable species must be removed by a method that insures root kill, and thereby prevent resprouting. Herbicides provide the only practical method of obtaining root kill. Records indicate that during the mid- to late 1950 s, the contractor Right-of-way Maintenance Corporation was making selective basal applications on the NYSEG transmission system. Dr. Frank Egler, an early proponent of selective vegetation management and the author of many articles and books on the subject, was a consultant to the Right-of-way Maintenance Corporation.

Development of more effective herbicides occurred in the 1960 s, namely picloram, along with a new method of application, the helicopter. The helicopter provided a means of economical herbicide application to large acreages in a short time, regardless of accessibility. During this decade, helicopter application became an important method of right-of-way maintenance on the NYSEG system, but aerial application never became the primary method of right-of-way maintenance. The average annual program was 400 acres, accounting for approximately 15% of the annual vegetation management expenditures.

With the end of the 1960 s came the environmental movement, and controversy surrounding the use of herbicides as a defoliant during the war in Southeast Asia. One of the environmental movement s concerns focused on the use of pesticides, causing a general concern on the part of the public over herbicide use on rights-of-way. Parallels were drawn between right-of-way maintenance practices and the Vietnam defoliation program by those opposed to herbicide use. Considering the unfavorable publicity associated with the use of herbicides on rights-of-way and dramatic increases in labor costs, it is not surprising that mechanized methods of vegetation maintenance received the attention of utility managers during the early 1970 s. Beginning in 1972, NYSEG cut several hundred acres of right-of-way with a hydro-axe. This is a rubber tired articulated vehicle with a large rotary mower mounted in the front. The advantage of this type of cutter over hand cutting was the increased production resulting in a lower cost per acre cut. There was also no adverse herbicide controversy to contend with. Disadvantages were the limitation in use, due to steep or rocky topography, the non-selective nature of the mowing, and the tremendous resprouting that follows mowing. Test plots established by NYSEG demonstrated increases of 400% in stem densities and resurgent growth of 10-12 feet in height in two growing seasons. It was concluded from these tests that the hydro-axe was an efficient cutting tool, but like hand cutting, problems arise from the resulting increased number of stems growing at accelerated rates.


During the period from WWII to the 1970 s many advances were made in the field of vegetation management. A vast array of herbicides and application techniques were developed. The chainsaw evolved as a reliable tool and mechanized mowing machines were developed, and utilities recognized the benefits of employing professional specialists trained in the field of vegetation management. Along with these many innovations and improvements came social pressures which complicated right-of-way management. The environmental movement fostered a widespread distrust of herbicides, and a concern for the way in which the right-of-way resources were managed.

The vegetation management cycle length has changed over the years. At RG&E, a three year maintenance cycle was begun in 1978 but that was subsequently lengthened to the existing six year cycle. NYSEG implemented an eight year cycle in 1980 for all regions except the lower Hudson Valley. A 6-year cycle was employed in this part of the NYSEG service territory due to its higher annual growth rates. Then in 2005 the rest of the NYSEG transmission system was shifted to a six year cycle.

B. Present Practices and Policies

As in the past, the primary goal of the Company right-of-way management program is to maintain the transmission system essentially free from outages caused by trees falling on or growing into the conductors. There are numerous methods and materials available to the foresters that can be used to accomplish this objective. It is the Company s policy to accomplish this objective while minimizing long-term vegetation management costs and maintaining the environmental quality of the area through management practices that are in harmony with existing land uses. The Company employs a vegetation management staff of professionals trained in the biological sciences whose job it is to implement this policy on the transmission system. Implementation is carried out through a prescription process whereby a treatment method is selected on a site-by-site basis that will maintain the reliability of the facility at the lowest long-term cost in a manner that is compatible with both on-site and adjacent land uses.

Methods available for maintaining the reliability of the system can be generally categorized as chemical and non-chemical. Experience has demonstrated that long-term vegetation management costs are more easily minimized through a program that employs chemical methods of control. This is due to the previously described ability of herbicides to root-kill undesirable vegetation, as opposed to mechanical non-chemical methods, which only temporarily retards growth, and often encourages re-growth at an accelerated rate. Therefore the Company practices are primarily chemical in makeup. Contrary to those who are generally opposed to pesticide use, it is possible to employ herbicides as part of the right-of-way management strategy without causing degradation of the right-of-way or adjacent environments. In fact, through properly prescribed herbicide treatments, the wildlife and aesthetic values and plant diversity may be enhanced. Selective


vegetation management practices protect and encourage shrub and herbaceous plant communities that are aesthetically pleasing and provide food and cover for many wildlife species.

The use of herbicides in an environmentally compatible manner begins with the selection of herbicides to be used as part of the program. Only products that are registered and labeled for use on rights-of-way by the U.S. Environmental Protection Agency and the N.Y. State Department of Environmental Conservation (or in Pennsylvania, the state Department of Agriculture) are used as part of the program. Registration is granted only after exhaustive testing of efficacy and potential acute and chronic hazards associated with the product. Once a product is labeled for right-of-way use, if it is deemed potentially useful by the Company Forestry personnel, an assessment of efficacy is made through test plot applications and limited commercial applications on the Company transmission system. If the product shows promise on this limited basis, it may be incorporated in the program and available for wider use on the system. The Company forestry staff continually monitors the scientific literature and attends workshops and seminars focusing on herbicides and vegetation management to stay current on information concerning these materials.

After a mechanical method or chemical product is selected for use by the Company, specifications are developed for its safe and effective use on the rights-of-way. For chemical methods, the specification is always at least as restrictive as the product label and is frequently more so. Procedures for handling and application are designed to protect applicators, the public, desirable vegetation, and such areas as croplands, waterways, residential and recreational areas that may be sensitive to herbicide exposure. The specifications for right-of-way maintenance define the available tools. The Lead Analyst Vegetation Management make the final decision on which technique to employ chemical or mechanical based on site conditions on and adjacent to the right-of-way. They also monitor the work, insuring it s satisfactorily completion in accordance with Company specifications, appropriate Federal and State regulations, and the goals of the right-of-way management plan. All herbicide applications on the Company transmission system are performed under the on-site supervision of a New York State Certified Pesticide Applicator. (See Appendix E, ROW Maintenance Worker Training and Protection of Sensitive Areas). Company specifications for vegetation management of the transmission right-of-way system are included in Appendix A.

C. Wire Zone / Border Zone Concept of Integrated Vegetation Management

The selective vegetation management approach described above that utilizes a variety of chemical and non-chemical methods of treatment has become known as integrated vegetation management (IVM). When IVM was first implemented on the Company system in the 1980 s, this management plan and the Company specifications used to carry out the plan included two lists of species: desirable


species to be retained and undesirable species to be removed. The list of desirable species was further differentiated: into low-growing shrubs that could be left anywhere on the right-of-way, and into tall shrubs and low-growing trees that could be left along the edge or near structures.

During the early years of implementing this selective approach, it became common practice to retain all species on the desirable list regardless of where they were located on the right-of-way. This resulted in the retention of tall shrubs and low-growing trees under the conductors. Retention of these plants accelerated the conversion from undesirable species to the more stable shrub community that was the program goal. So while the conversion has been successful on much of the Company system, it has also resulted in several issues:

The taller desirables, when left under the conductors, have reached heights that could result in contact with the conductors during the maximum sag under all rated operating conditions.

The taller desirables, when left under the conductors, conceal the presence of tall growing undesirable trees, especially in locations where the taller desirables have successfully established themselves in dense stands. When the undesirable trees eventually emerge above the canopy of the predominantly desirable vegetation, the time available to identify and remove them before they cause an outage is often very limited.

The taller desirables, when left under the conductors, make it difficult to obtain a clear view down the right-of-way to identify clearance problems. On some higher voltage lines, the conductors are configured horizontally, making it impossible to look across the right-of-way to determine clearances because the view is blocked by dense, tall-growing desirables.

Some shrub species that typically are not considered tall-growing have attained heights far greater than anticipated, causing clearance problems and hiding undesirable stems as described above. This could be because they are growing free of competition from tall growing trees that in a natural environment would shade out these shrubs, and cause them to die out. An example of a species capable of growing taller than anticipated is autumn olive, which can reach heights exceeding twenty feet.

An additional issue has resulted from successfully establishing a dense shrub community on the right-of-way. Access on the right-of-way for patrolling and vegetation management can be very difficult in the presence of such a shrub community. Maintaining a cleared access road or patrol path can solve the issue of providing access for patrols and of getting to structures for maintenance repairs. However, even with such roads or paths, vegetation management crews still have difficulty getting close enough to remove undesirable stems that are some distance from the road, and among dense stands of desirables.


Aside from the unanticipated problems identified above, the vegetation management program has been successful. The population of undesirable species has been greatly reduced, and replaced by a relatively stable low-growing plant community. The problems noted above demonstrate the need to identify voltage-specific minimum clearance zones, and to develop and adhere to a more conservative, (i.e. lower height) species list for the center portion of the right-of-way (AKA the wire zone).

The minimum clearance zone is the space around the conductor into which vegetation is not allowed to grow. The radius of the minimum clearance zone is the minimum clearance distance under all rated operating conditions. This is the distance necessary to prevent flashover between vegetation and conductors. The desirable species list for the wire zone consists of species with a mature height that will not will not intrude into the Minimum Clearance Achieved At The Time of Maintenance zone. The species list for the outer edges of the right-of-way, (AKA the border zone), consists of taller species that cannot fall into the Minimum Clearance Zone or intrude into the Minimum Clearance Achieved At The Time of Maintenance zone.

Management of the center portion of the right-of-way (the wire zone) that utilizes a lower-height species list than the outer portion of the right-of-way (the border zone) is referred to as the wire zone/border zone concept. This concept has been successfully implemented in other states, and was recommended as a best management practice in the FERC report that was issued after the August 14, 2003 blackout. Implementation of the wire zone/border zone concept is described in section 5 of this Plan.

For a more detailed discussion of the wire/border zone with regards to clearances, see Section 5.

4. Goals of the Right-Of-Way Management Plan

A. Maintain the Transmission System Free From Tree-Caused Outages

Vegetation shall be managed so that it is not a limiting factor in the continuous operation of the transmission system. This is to be accomplished by carrying out a regular maintenance and patrol routine that will identify and correct vegetation conditions that could potentially lead to line outages.

B. Minimize Long-Term Vegetation Management Costs By Encouraging the Development of Naturally Occurring, Relatively Stable, Low-Growing Plant Communities That Are Capable of Effectively Inhibiting Invasion By Tall-Growing, Undesirable Trees, Thereby Reducing the Density of Undesirable Tall-Growing Species Over Time


Site-specific prescriptions for attaining system reliability will be done in a manner that retains as much low-growing desirable vegetation as is physically and economically practical while removing undesirable tall-growing vegetation.

In sites where the conductor height ensures that a mature tree will not intrude into the Minimum Clearance Achieved At the Time of Maintenance distances or be able to fall into the Minimum Clearance Zone, tall-growing tree species may be retained on the ROW as long as there is no undesirable affect on access, construction, reliability, or public safety.

C. Maintain The Rights-of-Way In A Manner That Does Not Compromise The Quality Of The Environment

Company right-of-way management practices will be implemented in such a way that appropriate measures are taken to minimize adverse impacts on the environment.

D. Manage The Rights-of-Way In Harmony With Existing Land Uses

The vegetation management program will recognize and permit multiple uses of rights-of-way which are compatible with the reliable and safe operation of the transmission facilities and which allow for full compliance with all regulatory requirements.

E. Minimize Long-Term Vegetation Management Costs

Costs will be minimized by selecting the most economical, site-specific vegetation management techniques that will meet all other goals.

F. Minimize Herbicide Use

Overall herbicide use will be minimized by prescribing herbicides and methods of application that will effectively control undesirable species, maximizing retention of desirable species and also minimizing herbicide usage during future treatments.


5. Transmission Right-Of-Way Vegetation Management Procedures

It is the responsibility of the Company vegetation management staff to design and implement a program to accomplish the previously identified goals utilizing the methods and techniques described in this plan.

A. The Wire Zone / Border Zone Method and Clearances

As previously described this method consists of managing the right-of-way as two distinct zones. The center portion of the right-of-way or wire zone is defined as the floor of the right-of-way that is both underneath the conductors and a specified outer distance measured horizontally from the outermost conductors.

The wire zone outer distances are 15 feet beyond the outside conductors for bulk transmission lines and 10 feet beyond the outside conductors for non-bulk transmission lines.

The border zone is the outer portion of the right-of-way floor, extending from the outside edge of the wire zone to the edge of the specified right-of-way clearing width.

Wire

Zone

Border

Zone

Border

Zone

Edge of right of way clearing.

Edge of right of way clearing

Minimum Clearance Achieved at the Time of Maintenance


1. The Wire Zone

The wire zone will be managed in accordance with The Minimum Clearance Zone, The Minimum Clearance Achieved At The Time of Maintenance, and Visibility and Ease of Movement.

The Minimum Clearance Zone. The wire zone will be managed to retain herbaceous vegetation and woody species that cannot fall or intrude into the Minimum Clearance Zone. Minimum clearances are designed to prevent flash over between vegetation and overhead ungrounded supply conductors. At no time will vegetation be allowed to grow closer than the distances listed on Table 1, as measured from the maximum sag under all rated operating conditions.

Table 1 Voltage Minimum Wire Clearance under all rated

operating conditions* 34.5 & 46kV 3 feet

69kV 3 feet 115kV 4 feet 230kV 6 feet 345kV 10 feet

* based on IEEE 516-2003 table 5 and increased to the next whole number

The Minimum Clearance Achieved At The Time of Maintenance. The wire zone will be managed to remove all woody species whose mature height could intrude into the Minimum Clearance Achieved At The Time of Maintenance, as measured from the maximum sag under all rated operating conditions. These woody species must be removed at the time vegetation management work is performed. The distances are listed in Table 2.

Table 2 Voltage Minimum Wire Clearance under all rated

operating conditions 34.5 & 46kV 17 feet

69kV 18 feet 115kV 18 feet 230kV 21 feet 345kV 25 feet

Exceptions to The Minimum Clearance Achieved At The Time of Maintenance may be granted under the following conditions.

For <69kV lines, residential trees may be pruned/topped.

When easement restrictions preclude removal of the vegetation.

For non-bulk lines, exceptions may be granted for well maintained orchards, plantations, and nurseries. Exceptions will depend on wire


clearances. Any vegetation retained under this exception shall not, at a minimum, exceed 10 feet in height in the wire zone. Any vegetation retained under this exception on 69 kV to 115 kV shall not be topped or pruned.

These clearances, the Minimum Clearance Achieved At The Time of Maintenance and the Minimum Clearance Zone, are required to bring this Plan into compliance with the NERC Vegetation Management Standard FAC-003-1. These distances are measured under all rated operating conditions. See Appendix G, R.1.2.1 and R.1.2.2.

Visibility and Ease of Movement. The wire zone will also be managed to provide for visibility and ease of movement within the wire zone. Desirable vegetation within the wire zone will not be allowed to form a solid contiguous barrier that prevents a visual inspection either across or along the ROW to allow for identification of escaped undesirable stems under the conductors. Openings for ease of movement are necessary so that vegetation management workers can reach undesirable stems for treatment. The goal will be to keep up to 30% of the wire zone open or free of woody vegetation that matures at over five feet in height.

Example: a 345kV bulk transmission line, with mid-span conductor-to-ground clearances of 38 feet (at maximum sag) and Minimum Clearance Achieved At The Time of Maintenance of 26 feet can have shrubs with a mature height of up to 12 feet in that site. Shrubs capable of growing closer than that will be removed. As shrub densities in the wire zone exceed 70%, by span, taller growing shrubs may be targeted for removal in an effort to maintain visibility and ease of movement and access in the wire zone.

2. The Border Zone

The Minimum Clearance Zone. The border zone will be managed to retain herbaceous vegetation and woody species that cannot fall or grow into the Minimum Clearance Zone.

The Minimum Clearance Achieved At The Time of Maintenance. The border zone will be managed to remove all woody species whose mature height could intrude into the Minimum Clearance Achieved At The Time of Maintenance, as measured from the maximum sag under all rated operating conditions. These woody species must be removed at the time vegetation management work is performed.

Exceptions to The Minimum Clearance Achieved At The Time of Maintenance may be granted under the following conditions

For <69kV lines, residential trees may be pruned/topped.

When easement restrictions preclude removal of the vegetation.


For non-bulk lines, exceptions may be granted for well maintained orchards, plantations, and nurseries. Exceptions will depend on wire clearances and terrain. Any vegetation retained under this exception on 69 kV to 115 kV shall not be topped or pruned by the Company.

3. Mitigation Plans

Where easement or permit conditions limit the ability to completely remove undesirable vegetation from the ROW, a mitigation plan shall be developed to achieve sufficient clearances for the protection of the transmission facilities under all rated operating conditions. Any locations where the Minimum Clearance Achieved At The Time of Maintenance cannot be achieved will be inspected and treated as necessary to ensure that vegetation does not enter the Minimum Clearance Zone before the next scheduled treatment cycle. Inspection and treatment of these locations will be recorded on the Component Lines of the NYSEG and RG&E Transmission System list.

4. Undesirable Tall Growing Species

The following is a representative list of tall growing tree species that are considered undesirable in most right-of-way situations. Trees shall be removed from the right-of-way floor if the tree s mature height could (1) grow or fall into the Minimum Clearance zone (2) grow into the Minimum Clearance Achieved At The Time of Maintenance zone. See Section 5.A. 1 and 2 for possible exceptions to (2). All distances from the conductors shall be measured from the maximum sag under all rated operating conditions.

Undesirable Tall Growing Species Ash Hemlock Aspen, Cottonwood Hickory Basswood Hophornbeam Beech Maple Birch Mountain Ash Black Gum/Tupelo Oak Locust Pine Black Walnut Red Mulberry Butternut Sassafras Catalpa Spruce Cedar Sycamore Cherry Tamarack/Larch Chestnut Tree of Heaven Cucumber Tree Tulip/Yellow Poplar Elm Willow Fir


5. Tall Shrubs and Small Trees Primarily for the Border Zone

The following is a representative list of tall shrubs and small trees that may be compatible in the border zone of the right-of-way, except on narrower sub-transmission rights-of-ways. Since these species generally mature at a height greater than ten feet, they shall be removed from anywhere on the ROW floor if their mature height could (1) grow or fall into the Minimum Clearance zone (2) grow into the Minimum Clearance Achieved At The Time of Maintenance zone. See Section 5.A. 1 and 2 for possible exceptions to (2). All distances from the conductors shall be measured from the maximum sag under all rated operating conditions.

American Hornbeam Red Cedar Apple Scrub Oak Autumn Olive Shadbush Buckthorn Shrub Willow Choke Cherry Speckled Alder Common Pear Striped Maple Flowering Dogwood Sumac Hawthorn Witchhazel Hercules Club Witherod Nannyberry

6. Woody Shrubs

The following is a representative list of shrub species commonly found on rights-of-way across the service territory. These shrubs that generally mature at a height of ten feet or less While they are nearly always compatible in the border zone, in the wire zone some have the potential to grow closer to the conductors than the Minimum Clearance Achieved At The Time of Maintenance. If a given species is capable of growing tall enough to intrude into the Minimum Clearance Achieved At The Time of Maintenance, as measured the maximum sag under all rated operating conditions, it must be removed. See Section 5.A. 1 and 2 for possible exceptions.

Alternate Leaf Dogwood Jerseytea American Hazelnut Mapleleaf Viburnum Arrowood Mountain Laurel Beaked Hazelnut Mountain Maple Blueberry Redosier Dogwood Brambles Rhododendron Bush Honeysuckle Rose Common Elderberry Scarlet Elderberry Common Winterberry Silky Dogwood Gray Dogwood Spicebush Hobblebush Spirea

List continues on next page


Honeysuckle Sweetfern Huckleberry

Note that some of the species on these lists can be classified as either exotic, invasive and/or noxious particularly Autumn Olive and Multiflora Rose. In some situations management objectives within and adjacent to the right-of-way may warrant the removal of these species. Future discussions with State and Federal agencies to address invasive and exotic species on a landscape scale may require modifications of the current treatments for some species.

B. Selection of Vegetation Management Techniques

When selecting a technique, many factors are evaluated and their relative importance considered. These factors include:

Height, density, and composition of undesirable vegetation.

Susceptibility of undesirable vegetation to treatment techniques.

Density and composition of desirable vegetation.

Specific site conditions such as:

Land use

Presence of water bodies

Presence of sensitive crops

Accessibility

Visual Sensitivity

Soil Sensitivity

Relative costs of using various techniques on the specific site.

Past management activities.

Conditions subject to governmental regulation.

Easement restrictions

C. Definition of Vegetation Densities

The density of desirable and undesirable vegetation on the right-of-way is a very important factor when selecting a management technique. The following density classes, determined by a visual estimate, are used to describe woody vegetation:

Class % Ground cover Ultra Light Less than 100 Stems/acre

Light Up To 30% (100 to 1000 stems/acre) Medium 30 - 60% (1000 to 2000 stems/acre) Heavy > 60% (more than 2000 stems/acre)


D. Description of Vegetation Management Techniques and Conditions of Use

Each technique currently used is described below, along with the right-of-way conditions for which that technique will typically be prescribed. The Lead Analyst Vegetation Management utilize their professional judgment to assess the site conditions and select one of these techniques. Herbicide formulations that are utilized with the various techniques are included in the specification found in Appendix A.

1. Conventional Stem Foliar Technique

Using this technique, the entire stem and foliage of the target plant is thoroughly wetted to the point of run-off. The spray formulation is normally made up of a systemic herbicide in a water carrier. The herbicide enters the target plant primarily through absorption and translocates throughout the plant. Stem foliar sprays are applied during the growing season, after full leaf development and before dormancy begins. Stem foliar spraying that employs the proper herbicide formulation can be very effective in obtaining root kill, especially of root suckering species.

Stem foliar sprays are normally applied with hydraulic sprayers, equipped with 200 - 500 gallon tanks and two spray guns attached to hoses that are at least 100 feet long. Sprayers are mounted on 4-wheel drive or on all-terrain vehicles. Water is supplied to the spray vehicle with a 500 to 1000 gallon supply truck. The supply truck is not used for mixing or for transporting chemicals which ensures that sources of water used for spray operations will not be contaminated with herbicide. Stem foliar spray volumes normally range between 75 and 150 gallons of formula per acre. Over-spray is minimized by spraying at the lowest effective pressure from a distance no more than 10 feet from the target plant, by limiting applications to sites where the average height of undesirables is 15 feet or less, and by adding a drift control agent to the spray formulation. Some foliar spray formulations have the advantage of being selective in that they do not kill narrow-leaf herbaceous plants. The method is an efficient, economical technique for treating dense concentrations of undesirable vegetation. The stem foliar technique is utilized where brown-out of the vegetation is not a concern, and where:

Densities of undesirable species are medium to heavy.

Densities of undesirable species are light to medium, while desirable specie densities are scattered to light. This will result in smaller quantities of desirable vegetation being effected when utilizing the conventional stem-foliar technique.

Undesirable species are primarily root-suckering types which are most effectively controlled by foliar-applied techniques.

In addition, the following sites are not treated with the conventional stem foliar technique:


Within 50 feet of any stream or water body, or within 100 feet of a regulated wetland without a permit, or where specifically instructed by the Company Representative.

Within 100 feet of a potable water supply.

Within any orchard, nursery, or crop planting.

Within 10 feet of a fence which encloses an active pasture.

Within any area restricted by the herbicide label.

Any other special site identified by the Lead Analyst Vegetation Management.

2. Low Volume Foliar Technique

Using this technique, a concentrated waterborne herbicide formulation is applied in a uniform pattern to the top and leads on all sides of the target plant. Coverage must be uniform so that most leaves are treated but not to the point of run-off. The herbicide enters the tree through the foliage and translocates throughout the plant. Low volume foliar sprays are applied during the growing season, after full leaf development and before dormancy begins.

Low volume foliar sprays are applied with a pump-up backpack sprayer or with a motorized back-pack sprayer. Sprayers are equipped with at least two types of nozzles for treatment of trees of different heights. Low volume foliar spray volumes normally range between 5 and 10 gallons of formulation per acre.

Because of the low volume of spray that is applied, and the low pressure provided by the back-pack sprayer, this method can be very selective. This technique requires a less precise application than selective basal sprays, allowing for greater production while at the same time giving the applicator the ability to be selective. This technique is an ideal method for treating undesirable vegetation up to eight feet in height that is light to medium in density. Occasionally the technique is also used on taller target plants up to twelve feet in height, so long as the applicator is prudent in avoiding over spray. The low volume stem foliar technique is utilized where brown-out of vegetation is not a concern.

In addition, the following sites will not be treated with the low volume stem foliar technique:




Within active pastures unless the herbicide label specifically allows for this, and the property owner or farm operator approves of the application.




3. Basal Technique

Using this technique, the lower 12 - 18 inches of the stem of each target plant is thoroughly wetted with an oil-borne herbicide formulation. The purpose of the oil carrier is to facilitate bark penetration to carry the herbicide into the tree s system. To be effective, it is imperative that the treatment completely encircle the stem, and wet the root crown area and all exposed roots. Basal spraying is effective when applied at any time of the year, as long as snow or ice do not prevent spraying to the ground line. Since only the bottom 12 - 18 inches of each stem is treated and coarse sprays are used, this technique can be very selective with little chance of drift. The technique can also be very effective in achieving root-kill, except for several species that commonly root sucker after being top-killed. When performed during the dormant season, brown-out can be greatly reduced.

Hand-powered back-pack sprayers are used to apply the formulations. A wand or extension is attached to the spray gun, delivering the spray pattern directly to the target area and minimizing the size of the spray pattern. Historically, basal spraying has been more expensive than stem foliar spraying due to more intense labor requirements.

The selective basal spray technique is utilized where:

Densities of the undesirable species are light.

Densities of the undesirable species are light to medium, while the desirable densities are either light to medium or medium to heavy.

Brown-out of the vegetation that would result from selective foliar sprays would be objectionable.

The right-of-way agreement restricts the use of foliar techniques.

Target vegetation is in a pasture and must be treated during the dormant season when livestock is not present.

The site to be treated is inaccessible during the growing season due to the presence of crops and must be treated during the dormant season.

The target vegetation is located in a hedgerow or other area that is too close to sensitive crops to utilize a foliar technique.

Vegetation densities meet the criteria for foliar techniques, however the average height of the undesirable species is greater than 15 feet.

In addition, the following sites will not be treated with the selective basal technique:




Within active pastures.




4. Cutting and Stump Treatment Technique

Using this technique, individual stems are cut, and the resulting stumps and root collars are treated with an herbicide to prevent resprouting. Cutting is usually performed with a chainsaw or a brush saw. An oil borne herbicide is applied to wet the outer perimeter of the stump, the bark, and all exposed roots. Water borne formulations are applied only to the cambium of the cut surface. The application equipment for oil borne formulations is the same as for the basal technique, described in the previous section. For water borne applications, a hand held squirt bottle is used.

Stump treatment prevents the emergence of dormant buds from the stump and the root collar; however stump treatment does not normally prevent root-suckering species from sprouting from dormant buds located along the root system. Vegetation that is cut using this technique is disposed of using several methods, depending on the sensitivity of the site. The following methods are listed in order of increasing cost:

Lop and Scatter Vegetation is felled and cut up so that it is in close contact with the ground. Access roads or a swath under the conductors is kept free of such cut vegetation to ensure access is not hindered.

Windrow Vegetation is cut and piled away from structures and outside of the access road.

Chipping Vegetation is cut and then reduced to chips with a brush chipper. Chips are normally left on site.

Off-Site Disposal Vegetation is completely removed from the site, although in some cases it may be moved to another site on the right-of-way.

Due to the additional labor required for cutting the vegetation, this technique is more costly than the basal technique. The cutting and stump treatment technique is utilized where:

Standing dead stems would be objectionable due to aesthetic concerns.

Clearance concerns exist where cutting is required to address the concern; i.e. the retention of tall treated stems that result from using one of the other methods would not leave adequate clearance.

The right-of-way agreement requires that cut vegetation is to be removed.

The presence of foliage that is potentially toxic to livestock requires that the vegetation either be cut during the dormant season, or cut and removed during the growing season.

Vegetation to be removed is too tall to foliar spray (>15 ) and density is too high for cost effective basal spraying.

In addition, the cutting and stump treatment technique will not be used on the following sites:





Within active pastures unless the herbicide label specifically allows for this, and the property owner or farm operator approves of the application.



5. Cutting/Pruning Technique (with no herbicide treatment)

Using this technique, undesirable vegetation is either cut down or partially removed by pruning those portions of the tree that are capable of intruding into the Minimum Clearance Achieved At The Time of Maintenance. Pruning is normally performed by using the drop-crotch or natural trimming technique where the limbs to be removed are cut back to the next lateral limb. The tree workers either manually climbing the tree or utilize aerial lifts. Cut vegetation is disposed of in the same manner as the cutting and stump treatment technique, described in the previous section. Cutting and pruning are labor intensive techniques, and to control re-growth, they must be repeated on shorter rotations than techniques using herbicides. Hence this technique is less cost effective than techniques employing herbicides.

The cutting/pruning technique is utilized where:

The undesirable vegetation is located in a sensitive area such as residential lawn, park, etc. However, for 69kV and above lines, unless there is an easement restriction, there will be no pruning of target vegetation that is rooted within the specified ROW clearing width. Said vegetation must be cut down.

The ROW agreement restricts the use of herbicides.

Company specifications restrict the use of herbicides.

Side encroachment exists on a site where the ROW agreement will not allow for the total removal of the targeted vegetation.

6. Mechanical Mowing Technique

Using this technique, the vegetation is cut with a large mowing machine attached to an all-terrain vehicle. The cutting swath is normally about 8 feet wide, making the technique relatively non-selective. Where the terrain allows for the use of this equipment, mechanical mowing is more cost-effective than hand cutting. If herbicides are not used in conjunction with mechanical mowing, the resulting re-growth will necessitate a short rotation, increasing the cost of using this technique compared to using other techniques that employ herbicides.

Mechanical mowing is utilized where the terrain is accessible to mowing equipment and:

The use of herbicides is restricted, and the acreage is large enough to make the use of a mowing machine economically feasible.


The density of the target vegetation meets the same criteria as the conventional stem foliar technique; however the average height of the target vegetation is over 15 feet. Under these conditions, mechanical mowing would be followed up where possible either by a stem foliar application after resprouting has occurred, or by using a mower that also applies herbicide to the cut surface of the mowed stubble.

E. Hazard Tree Program

Hazard trees are located outside of the specified clearing width of the ROW. These trees pose a threat to the reliability of the line. In order to threaten the line, the tree must be sufficiently tall to strike the line if it falls and it must exhibit one or more of the following characteristics that would make it likely to fall:

The tree displays excessive lean toward the line.

The tree is diseased or has a defect that increases the risk that it will fall toward or into the conductors.

The root system is shallow due to moisture conditions or species characteristics, making wind throw a concern.

1. Hazard Tree Identification

Experience has shown that individual hazard trees are difficult to identify. Often trees that fall into the right-of-way that strike the conductors exhibit no outward characteristics that would have identified them as a hazard tree ahead of time. In other instances, a large tree located far outside the ROW (10 +) will fall and start a chain reaction that results in an otherwise sound or healthy tree along the edge being pushed into the conductors.

The hazard tree program starts at the time a line is built by clearing a right-of-way to a standard width that provides reasonable protection. The wider the right-of-way is initially cleared, the lower the probability that a tree falling into the right-of-way will hit the conductors. The Company has an ongoing effort to widen existing narrow rights-of-way, either to the standard width or to the maximum allowed by the easement, which ever is less.

Company Standard Right-Of- Way Dimensions

Voltage Standard ROW Width 34.5kV to 69kV 100 feet

115kV single pole construction 100 feet 115kV H-frame / steel tower construction 125 feet

230kV H-frame construction 150 feet 345kV H-frame construction 175 feet


2. Hazard Tree Inspection Schedule

In addition to these widening efforts, every transmission line is inspected for hazard trees annually. The number of inspections is prioritized by voltage, with the bulk and any critical lines receiving the most inspections (NYSEG and RG&E do not currently have any 115kV deemed critical lines). The inspection schedule is as follows:

Voltage Class

Aerial Patrol

Ground Patrol

Vegetation Inventory & Follow-up Inspection

345 & 230kV Lines & any < 230kV critical lines

1 per year 1 per year 2 every 6 years

< 230kV Non- Critical Lines

1 per year 1 every 5 years 2 every 6 years

3. Hazard Tree Removal

By definition all hazard trees represent a threat to line reliability. Hazard tree removal is scheduled in accordance with the level of threat they represent. Some hazard trees represent an immediate threat to the line, such as trees that are leaning toward the line as a result of wind storms, flooding etc. Hazard trees posing such a threat are likely to fail at any time, even without the influence of additional forces such as wind, ice or snow load. Other hazard trees represent a long term threat, in that these trees may be dead and fail over time as they decay, losing their structural integrity; or they may have a defect or weakness that makes them vulnerable to failure during a storm event.

Immediate Threat Hazard trees that are deemed an immediate threat are cut as soon as possible; however, in most cases, a tree presenting such a threat will require that the line be de-energized before the tree can be cut safely without endangering personnel or damaging the line. Once the hazard tree is identified, Regional Operations will determine whether to apply for a scheduled or emergency outage. If it is determined that an emergency outage is warranted, Regional Operations will coordinate the outage with the Energy Control Center (ECC) and the tree will be removed in accordance with the NYSEG and RG&E Accident Prevention Manual as soon as the line can be de-energized. If it is determined that the line must be de-energized but an emergency outage is not warranted, Regional Operations will submit an application for an outage to the ECC and the tree will be removed according to the schedule that is established.

Long Term Threat Hazard trees that pose less than an immediate threat shall be cut as soon as arrangements can be made for removal, including a determination by Regional


Operations as to whether an outage is necessary or a Hot Line Clearance, scheduling a crew to do the removal, and securing the necessary rights if the easement does not have provisions for removing hazard trees. In some cases, cutting may be deferred for a time to take advantage of an outage that has already been scheduled for purposes other than the tree removal. In any case, hazard trees shall be removed before the next scheduled patrol.

4. Budgeting For Hazard Tree Removal

In order to maintain reliability, funds may be shifted from other less critical activities in order to fund hazard tree removal.

6. Planning the Annual Vegetation Management Program

The Manager Vegetation Management-Transmission in conjunction with the Lead Analyst Vegetation Management develops an annual vegetation management program for the divisions based on the objectives that are consistent with the long-term system wide goals identified in this plan.

A. Maintenance Cycle and Relationship to Goals

Because of its dynamic nature, right-of-way vegetation must be maintained on a periodic cycle to insure the reliable operation of the transmission system. The length of the cycle should be established so that the interval between treatments prevents any vegetation from reaching a height that could threaten reliability. Conversely, a cycle length that is too short results in unnecessary maintenance expenditures without any gain in reliability.

The Company s annual program is based on a 6-year cycle. In any 6-year period, every acre on the system supporting woody vegetation receives a maintenance treatment. Completion of the 6-year cycle is accomplished by treating approximately one-sixth of the total system every year.

B. Determination of Rights-of-Way To Be Treated

Each forester identifies the rights-of-way within the divisions that are to be included in the annual vegetation management program. Rights-of-way to be treated will be identified early during the year prior to treatment. This allows for adequate time to assess each right-of-way in detail, and to develop a cost estimate to include in the following year s budgets. Rights-of-way will be selected for inclusion in the annual program based on electrical clearance standards and with the objective of treating approximately one-sixth of the system per year.


1. Right-of-Way Treatment Determinations Based on Electrical Clearance

Criteria

To insure that the transmission system is free from tree-caused outages, minimum clearances shall be maintained within the active ROW, under all rated operating conditions, that will prevent arcing or an electrical flashover between the conductors and the vegetation that could result in a line outage. To meet this reliability goal, the clearances identified in the table below shall be met. The clearances listed as Priority #1 shall also represent the Minimum Clearance Distances required to bring this plan into compliance with the NERC Vegetation Management Standard (see Appendix G, item R1.2.2).

Priority #1 Contact Regional Operations to arrange for immediate removal (1)

Voltage (kV)

Clearance (2)

(from vegetation) 35 4 or less 46 5 or less 69 5 or less

115 5 or less 230 6 or less 345 10 or less

(1) Immediately after identification, Regional Operations shall be contacted. Regional Operations shall determine if safe removal of the tree will require an emergency outage or a scheduled outage. Based on this determination Regional Operations shall contact the ECC and request the appropriate outage. Regional Operations will coordinate removal of the tree with the Division Forester.

Priority #2 Shall be cut before next growing season after identification

Voltage (kV)

Clearance (2)

(from vegetation) 35 > 4 and < 8

46 > 5 and <9

69 > 5 and < 9

115 > 5 and < 9

230 > 6 and < 10

345 > 10 and < 14


(2) Clearance is measured from the vegetation to the conductor location under all rated operating conditions

Priority #3 Shall be cut before 2nd growing season after identification

Voltage (kV)

Clearance (2)

(from vegetation) 35 > 8 and < 12

46 > 9 and < 13

69 > 9 and < 13

115 > 9 and < 13

230 > 10 and < 14

345 > 14 and < 15

(2) Clearance is measured from the vegetation to the conductor location under all rated operating conditions.

In addition to these basic electrical clearances, the following items are also factored into the determination of when to schedule treatment:

The effect of maximum wire sag during high conductor temperature.

The effect of wire swing during high wind conditions. The annual vegetation management program will include correcting all conditions that are identified as requiring treatment based on the above electrical clearance criteria. If the electrical clearance criteria require treatment at only a few scattered locations on a given right-of-way, those locations will be spot-treated. The remainder of the right-of-way will be scheduled for treatment based on the six year cycle. When the electrical clearance criteria are violated at several locations, the entire right-of-way will be scheduled for treatment based on the priority ratings 1, 2, or 3. Except where emergency spot-treatment is required, rights-of-way will generally be treated from substation to substation, or in other contiguous segments defined by division boundary or from substation to junction with another right-of-way, etc.

2. Determination of Right-of-Way To Be Treated Based on Maintenance Cycle

The annual vegetation maintenance program for each division will be approximately equal to one-sixth of the total division acreage. In addition to treatment of one-sixth of the division acreage, all locations requiring treatment because of electrical clearance criteria shall also be included in the annual division program. The schedule for the six year cycle shall include one treatment of all the right-of-way acreage in the division within a six year period.


C. Vegetation Line Patrols

All transmission lines are patrolled on a scheduled basis and, as needed, on an emergency basis. Patrols may be either aerial (by helicopter) or ground patrols.

1. Scheduled Patrols

The purpose of scheduled patrols is to identify hazard trees along the ROW edge and to identify locations of Priority #1 and #2 clearances between trees and conductors. The schedule is as follows:

Voltage Class

Aerial Patrol

Ground Patrol

345 & 230kV Lines & any 115kV critical lines*

1 per year during spring-summer

1 per year

< 230kV Non- Critical Lines

1 per year during spring-summer

1 every 5 years

*Any 115kV transmission lines determined to be critical as defined by the Northeast Power Coordinating Council (NPCC) are to be patrolled twice annually. However, NYSEG and RG&E do not currently have any 115kV deemed critical.

During the spring-summer aerial patrol, the foresters will record any suspected Priority #1 and Priority #2 clearances between the vegetation and conductors (see Section 6, part B, subpart 1. for definitions of Priority # 1 and 2 conditions) and hazard trees. They will also observe the general vegetation conditions on the right-of-way. Suspected Priority #1 and Priority #2 and hazard trees will be investigated on the ground. During the ground patrols, the vegetation inspector will record any suspected Priority #1 or #2 clearances and any hazard trees.

If the vegetation inspector identifies a suspected Priority #1 condition, Regional Operations and the division forester will be notified immediately. For all other conditions, standard patrol forms will be submitted to the division forester within two weeks of completion of the patrol. Standard forms will be used to record aerial and ground patrol inspections and will be reviewed by the division forester. The forester will take the necessary action to correct Priority #1 and #2 conditions in accordance with Section 6, part B, subpart 1 of this plan. Any hazard trees that are identified will be removed in accordance with Section 5, part E, subpart 2, (found on page 27).

2. Emergency Patrols For Lines Operating At 69kV and Higher Voltages

Whenever an unexplained outage occurs on a 69kV and above transmission line, the System Operator will contact the Division Line Department to inform them of the line outage and to initiate an investigation into the cause of the outage. If it is determined that the problem causing the outage is tree-related, the forester is


notified by the Line Department. The forester will then investigate any such tree-caused outages, and for 69kV and above, file a Tree-Caused Transmission Outage Report (see Appendix H) with the Manager Vegetation Management-Transmission to document the circumstances that led to the outage. If a vegetation caused outage occurs on a 115kV and above transmission line the outage must be reported to the NPCC within 48 hours (See Appendix G, NPCC-CGS-001: Reporting of Vegetation Contacts Within 48 Hours).

D. Detailed Right-of-Way Inventory, Program Design and Record Keeping

After the rights-of-way that are to be included in the annual vegetation management program have been identified, the forester conducts a detailed vegetation inventory of each right-of-way, determining the method of treatment to be employed on each site. All pertinent information concerning the ROW width, special conditions and restrictions will be reviewed by the forester and factored into the treatment design. The inventory information is recorded in a geographic information system (GIS) based vegetation management system (VMS) that ties all of the information to a map location.

1. VMS Inventory

During the VMS inventory phase the ROW is divided into management units. A management unit is a segment of ROW, shown as a polygon on the VMS map, with similar site conditions such as vegetation and land use, which can be treated using the same management technique. When a change in site condition warrants a change in the management technique, a new management unit is designated. Management units are assigned a unique ID number. Each management unit is described in terms of land use, height and density of incompatible vegetation, density of compatible vegetation, ROW restrictions, special instructions, and prescribed treatment and the area in acres. VMS maps showing the management units are provided to the contractor and serve as instructions for completing the vegetation maintenance work.

2. VMS Treatment

As the work is completed, treatment information is gathered for entry into VMS. This includes the date the work was performed, type of treatment performed, herbicide formulation and quantity applied, any changes from the original treatment prescription, contractor name, and applicator name. This provides a permanent record of the work.

E. Budget Development

The VMS inventory data provides an estimate of the volume of work to be done during the year. Estimated unit costs are applied to the VMS estimated volume of work to determine a budget for the upcoming year.


F. Program Review

The annual program for each division will be submitted to the Manager Vegetation Management-Transmission to ensure compliance with the objective of treating at least one sixth of the system acreage.

7. Implementing the Annual Vegetation Management Program

Due to the seasonal nature of vegetation management work, it is economically prudent to employ contractors to perform this work. These contractors are capable of providing specialized labor, equipment, materials, and supervision necessary to perform this work on an as-needed basis. Occasionally Company personnel are used to perform unscheduled emergency work.

A. Selection of a Contractor

Contractors are selected to complete the maintenance program through a competitive bidding process. The work can be bid on a unit price basis for a multi-year contract or the work can be bid for a lump sum amount based on the specific VMS inventory for a one year contract.

B. Program Monitoring

The program is administered in the field by foresters. On a system wide basis, the Corporate Forestry staff monitors the program.

1. Scheduling

The foresters work out scheduling with the contractor foremen performing the work, to insure all work is completed within seasonal and contractual parameters.

2. Specific Instructions

The foresters insure that all work is completed in compliance with the Company specifications and with any other specific instructions that apply to the job. Any significant change in work instructions is authorized by the appropriate forester in writing.

3. Work Reports

The contractor foreman provides the Company forester with work completion data as the work progresses. This data is a record that the work was completed on a site by site basis as specified on the VMS maps or in accordance with an approved change in treatment type. The data is entered into VMS as the work progresses. At the end of the job there should be a treatment record for each


management unit along the right-of-way.

4. Monitoring of Work in Progress

To insure the work is completed in compliance with the specifications, the foresters frequently spot check the work in progress. Particular attention is paid to handling and application of herbicides in relation to Company specifications and all state and federal regulations. The forester will assure that all spray personnel are familiar with and understand the work specifications and instructions.

5. Landowner Inquiries and Concerns

Any right-of-way management inquiries or concerns from landowners that are received by the contractor shall be forwarded to the appropriate Company forester. The forester will consult with the real estate department and/or the legal department, to determine if there are any restrictions. For any such inquiry or concern that cannot be promptly resolved by the contractor, the forester will contact the land owner as soon as possible, attempting to address the inquiry or concern in a timely manner.

C. Quality Control and Guarantee

1. Completion

Before payment for any work is released, the responsible forester must be satisfied that:

All specified cutting has been satisfactorily completed.

All specified herbicide applications have been satisfactorily completed.

Documentation of work completion is accomplished through VMS treatment data entry.

2. Guarantee

By August 1 of the year following initial treatment, the contractor guarantees in writing that the work has been completed in accordance with the specifications. (See Section 7 of Appendix A, NYSEG and RG&E Specifications for Vegetation Management).

D. Record Development

Upon completion of the annual right-of-way management program, the responsible forester will review the VMS treatment data for each line in the program to ensure that there is a record of treatment for each site where work was


specified. This information will be used to generate reports to fulfill regulatory reporting requirements.

8. REGULATORY REQUIREMENTS

In carrying out the annual vegetation management program, regulations of the following federal, state, and local regulatory bodies will be complied with.

A. U.S. Environmental Protection Agency (EPA)

The EPA is the federal agency that administers the Federal Insecticide, Fungicide, and Rodenticide Act, or FIFRA. The Act covers the manufacture, sale, and use of all pesticides. Herbicide applications on the COMPANY system are performed by contractors who, by law, are obligated to comply with FIFRA. The COMPANY vegetation management staff, in writing specifications, prescribing right-of-way treatments, and in supervising vegetation management operations, will insure that all such operations are performed in compliance with FIFRA.

B. New York State Department of Environmental Conservation (DEC)

1. Bureau of Pesticide Management

This bureau of the DEC is responsible to the EPA for the certification and enforcement of FIFRA and State rules and regulations (6NYCRR 325) relating to the manufacture, sale, and use of all pesticides within New York State. The COMPANY vegetation management staff, in writing specifications, prescribing right-of-way treatments, and in supervising vegetation management operations, will insure that all such operations are performed in compliance with 6NYCRR 325.

The Bureau also administers Article 33 of the Environmental Conservation Law, relative to applicator certification, herbicide notification and posting requirements for landowners and the general public. The Company complies with the requirements of Article 33 as they apply to utility rights-of-way, and through its specifications directs its contractors to be in compliance with the certification, notification, and posting requirements of Article 33.

On a voluntarily annual basis, the New York State Department of Environmental Conservation regional offices are notified of all scheduled electric transmission vegetation maintenance projects that include herbicide applications in their counties/regions. The intent of the list is to aid the DEC in responding to any herbicide inquiries regarding the Company s program. They are sent a list of lines and the planned herbicides formulations.


2. Bureau of Lands and Forests

This bureau of the DEC is responsible for the protection of the forests of the State from fires, and has declared certain towns within the State as firetowns. ECL Sections 9-1105 and 9-1107 regulates the disposal of cut vegetation within these towns that may constitute a fire hazard. Within designated firetowns, the COMPANY vegetation management staff will ensure that cut woody vegetation is disposed of in compliance with ECL Sections 9-1105 and 9-1107.

C. New York State Public Service Commission (PSC)

The PSC is charged with regulating the utilities of the State. Summarized below are sections of Part 84, Transmission Facilities Management Statutory Authority: Public Service Law, Section 65(1), 66(2), through which the PSC regulates right-of-way management operations:

84.2 - Submit to the PSC for its review and approval a long-range right-of-way management plan for the electric transmission system.

84.3 - Prepare and file with the PSC, by March 31 of each year, (1) a systemwide description of the vegetation maintenance program and schedule of work to be done in that year and (2) an herbicide application filing in a format to be provided by Staff, including the amount and cost of herbicide applied, by acre and technique, for each application management type employed.

Article VII of the New York State Public Service Law

Vegetation management activities on electric transmission lines that were licensed under Article VII of the Public Service Law have been subsumed into this Plan. Any specific restrictions or requirements that apply to vegetation management on these rights-of-way appear on the plan and profile drawings and will be complied with during maintenance activities.

Order Requiring Enhanced Transmission ROW Management Practices By Electric Utilities Case 04-E-0822 June 20, 2005

Ordering Clause 7 Submit to the Secretary annually by March 31, or as the Secretary may require, for Staff s review, an original and two copies of a report, discussing the amount of danger tree work completed by line in the preceding calendar year. Reported data shall include line name or number, miles trimmed and/or number of trees removed, and program expenditure.

Ordering Clause 8 Investigate, record, and submit to the Secretary, for Staff s review, an annual report by March 31, discussing each vegetation-caused outage in the preceding calendar year. Vegetation-related outages that result from


vegetation falling into lines from outside the ROW that result from natural disasters shall not be considered reportable. Examples of disasters that could create non-reportable outages include, but are not limited to earthquakes, fires, tornadoes, hurricanes, landslides, wind shear, ice storms, floods, or major storms as defined by the PSC. Also, vegetation-related outages due to human or animal activity shall not be considered reportable. Examples of human or animal activity that could cause a non-reportable outage include, but are not limited to, logging, animals severing tree, vehicle contact with tree, arboricultural activities or horticultural or agricultural activities, or removal or digging of vegetation. Information for each outage in voltage classes 69kV and above shall include line number, location (i.e. tower number), tree location (i.e., inside or outside the ROW), species height, condition, distance from conductor to base of tree, slope, and weather condition at the time of the outage.

Case Number 10-E-0155 May 27, 2011

All companies shall submit, for staff review and acceptance, updates to their websites and any printed materials, detailing the rationales and practices governing their ROW management programs.

All companies shall establish a direct line of communication between the public and the companies vegetation management personnel for questions regarding ROW vegetation management work. Information advising of the opportunity for such communication and how such communication can be accessed shall be made available on the companies websites, on all required notifications, and provided by field personnel and contractors upon request.

All companies shall develop sections in their Commission approved ROW Management Plans, for staff review and acceptance, to address the circumstances and criteria pursuant to which replanting is warranted.

All companies shall develop, if one does not exist or enhance if one does, a section in their plans detailing when and where various types of vegetation will be allowed to remain on a ROW. The section shall incorporate, to the extent possible, a vegetation management approach that recognizes that removal of desirable species is neither required nor preferred. Commensurate training and oversight of field personnel shall also be addressed.

D. Pennsylvania Department of Agriculture, Bureau of Plant Industry

This bureau is charged with the enforcement of FIFRA and the Pennsylvania Pesticide Control Act relating to the manufacture, sale, and use of all pesticides within the Commonwealth of Pennsylvania. For rights-of-way within the


Commonwealth of Pennsylvania, the Company vegetation management staff, in writing specifications, prescribing right-of-way treatments, and in supervising vegetation management operations, will insure that all such operations are performed in compliance with such regulations.

E. Pennsylvania Department of Environmental Resources (DER)

Vegetation maintenance activities on the Company rights-of-way that cross state forest lands within the Commonwealth of Pennsylvania are subject to the approval of the DER. Before any such activity is undertaken, the appropriate DER district forester is contacted and provided with information seeking consideration and approval of the activity.

F. Pennsylvania Game Commission

Vegetation maintenance activities on the Company rights-of-way that cross State Game Lands within the Commonwealth of Pennsylvania are subject to the approval of the Game Commission. Before any such activity is undertaken, the appropriate Game Lands Manager is contacted and provided with information seeking consideration and approval of the activity.

G. New York City Department of Environmental Protection, Bureau of Water Supply (DEP)

Prior to performing any herbicide applications on lands of the NYCDEP, Bureau of Water Supply a permit is obtained from the DEP. At the same time, notification is provided for applications within the watersheds of the DEP that are not on lands owned by the DEP. The notification provides the same information as a permit application. This information can be used by the DEP in their efforts to monitor pesticide applications within their watersheds.

H. Northeast Power Coordinating Council (NPCC)

In support of compliance with FAC-003 above, the Company is subject to NPCC Compliance Guidance Statement CGS-001-R: Reporting Vegetation Contacts within 48 Hours. The procedure to ensure compliance can be found in Appendix I.

I. North American Electric Reliability Corporation (NERC)

The Company transmission vegetation management program must be implemented in accordance with the requirements of the NERC Vegetation Management Standard FAC-003-1 as found in Appendix G of this plan.


9. General Budgeting Requirements

The NYSEG annual budget and the RG&E annual budget are designed to include treatment of all acreage where priority #1 and #2 clearances have been identified (as per Section 6, part B, subpart 1), and approximately one-sixth of the system wide wooded right-of-way acreage (as per Section 6, part B, subpart 2).

The budget required to perform this work is estimated based on costs experienced in past years, plus anticipated inflationary costs. The overall average cost per acre for the annual program will depend on the mix of methods prescribed for treatment. At all times, the method prescribed will be the most economical option that will accomplish the goals identified in this plan. The budget amount also includes the cost of hazard tree removal, widening and hot spot work.

10. Plan Evaluation, Review, and Updating

A. Evaluation The success of the plan is measured against the goals it is designed to accomplish:

1. Maintain the Transmission System Free From Tree-Caused Outages

Assessment: Tree-caused outages are monitored by the Manager Vegetation Management-Transmission. Outages on 69kV and higher lines are formally investigated. This monitoring process helps to identify any needed modifications to the plan.

2. Minimize Long-Term Vegetation Management Costs By Encouraging the Development of Naturally Occurring, Relatively Stable, Low-Growing Plant Communities That Are Capable of Effectively Inhibiting Invasion By Tall-Growing, Incompatible Trees, Thereby Reducing the Density of Undesirable Tall-Growing Species Over Time.

Assessment: The success of the plan in accomplishing this goal is monitored over the long term by comparing vegetation inventories from one cycle to the next. Over the long term, the density of tall-growing target species should decrease or at least remain flat, while the densities of desirable species increase. As this occurs, costs per acre treated should decrease or at least remain stable, providing another method of evaluation.

3. Maintain The Rights-of-Way In A Manner That Does Not Compromise The Quality Of The Environment.

Assessment: The success of this goal will be judged by assessing the public comment or concerns received, and also in any regulatory action that potentially results from such concerns. Any feedback from PSC staff that result from their annual field reviews will also be a measure of success. The Lead Analysts


Vegetation Management will also make observations in the field, and review current literature, as part of an on going evaluation to assure that this goal is being met.

4. Manage The Rights-of-Way In Harmony With Existing Land Uses.

Assessment: This goal will be measured primarily through assessing the comments and concerns received from property owners, property users, and the general public.

5. Minimize Long-Term Vegetation Management Costs.

Assessment: This goal will be assessed by reviewing costs. Annual treatment cost records will be monitored and analyzed, both on a yearly basis, and on a cycle vs. cycle basis to assess the cost trends.

6. Minimize Herbicide Use.

Assessment: This goal will be assessed by reviewing the quantity of herbicide applied per acre of ROW treated on an annual basis. Annual treatment application records will be monitored and analyzed, both on a yearly basis, and on a cycle vs. cycle basis.

B. Review and Updating

The Company reviews its work specifications regularly to assure they are effectively meeting the program objectives. Whenever the Company work specifications are modified, they are sent to the Commission Staff to likewise be considered an update of this plan. In addition, the Company will periodically review and assess the plan at least every six years, or two complete cycles, whichever comes first. Subjects to be reviewed include but are not limited to reliability, cost, herbicide use, and customer concerns.

Any proposed changes to the plan will be brought to the attention of the PSC Staff. Minor changes to the plan will be those having no significant adverse impact to reliability or to the environment (including public health). Minor changes to the plan will be referred to the Commission Secretary by the PSC Staff. All other proposed changes would be considered major and will be referred to the Commission for action pursuant to the State Administrative Procedures Act.

11. Present and Anticipated Research Activities

In the past, research in right-of-way management was undertaken primarily through utility funded research organizations at the national and state level and through the efforts of individual utilities. At the national level the Electrical Power Research Institute (EPRI) continues to carry out or fund research and development projects in


the area of right-of-way management under the voluntary sponsorship of the nation s utility industry including NYSEG. At the state level the Empire State Electric Energy Research Corporation (ESEERCO) has disbanded. In the past ESEERCO was the organization that facilitated most of the research funded by the investor owned utilities of New York. To fill the gap left by ESEERCO, Niagara Mohawk Power Corporation (NMPC) partnered with SUNY-ESF in 1998 to continue research on electric transmission vegetation management. In 2001 NYSEG joined this partnership to provide support for new studies and expand on-going studies. In addition to funding research at the national level through EPRI and at the state level through the partnership with NMPC and SUNY-ESF, NYSEG has funded some small projects on an individual basis.

A. Electric Power Research Institute (EPRI)

EPRI began operations in 1973 for the purpose of expanding electric energy research and development under the voluntary sponsorship of the nation s utility industry public, private and cooperative. Its goal is to develop a broad coordinated, advanced technology program for improving electric power production, transmission, distribution and utilization in an environmentally acceptable manner. Current projects in right-of-way management are listed below.

1. Shrub Community Dynamics On A Powerline Corridor In Upstate New York This project was done under the previously mentioned partnership with NMPC, NYSEG and SUNY-ESF. There were three studies under this project: 1) The life histories of common ROW shrubs Cornus, Rubus and Viburnum. 2) The factors influencing the distribution and abundance of shrubs on powerline ROWs and 3) How cultural treatments can increase and maintain the presence of desirable shrub communities.

2. Select Shrub Life Histories: An Annotated Bibliography This project was done under the previously mentioned partnership with NMPC and SUNY-ESF. The objective was to develop an annotated bibliography that contains important references for understanding the life histories of common shrubs.

3. Factors Influencing The Distribution And Abundance Of Shrubs On ROWs In New York State The Objective of this study is to explore and determine what factors have the greatest influence on the distribution and abundance of shrubs on powerline ROWs across New York.

4. Assessment Of Cultural Treatments To Increase And Maintain The Presence Of Desirable Shrub Communities: A Manipulative Field Study The objective of this study was to determine what cultural treatments and by what mechanisms can the presence of desirable shrub communities be increased and maintained on ROWS.


B. New York State Electric and Gas Corporation (NYSEG)

The following studies were either funded by NYSEG as part of the partnership with NMPC and SUNY-ESF or funded independently:

1. Competitive Hierarchies Of Desirable Plant Communities

The objective of this study was to study the ability of various desirable plant communities to inhibit the seedling establishment, survival, and growth of undesirable tree species.

2. Herbicide Deposition Patterns For Commonly Used Treatment Schemes The objective of this study was to quantify the amount of herbicide used to treat varying densities and sizes of trees and to quantify the amount of overspray that results for conventional methods/application techniques.

3. Herbicide Deposition Patterns For Commonly Used Treatment Schemes

Impacts On Community Structure And Composition In The Near-And-Long Term The purpose of this study was to quantify the area affected by the overspray shadow and to assess the impacts that the overspray has on the vegetative community soon after treatment and over time.

4. Density, Diversity And Nesting Success Of Birds On Managed Shrublands Of Northeastern United States: The Importance Of Utility Rights-Of -Way This study analyzed the contribution of managed shrublands, primarily utility rights-of-way, to the support of the declining guild of shrubland birds.

5. Analyses Of Vegetative Management And Its Effects On Avian Biodiversity On ROW The objective of this study was to determine if removal of non-native, invasive shrubs increases avian biodiversity.

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