FOREST SERVICE NATIONAL DESK GUIDE TO PREPARING VEGETATION MANAGEMENT PROCEDURES FOR ...a123.g.akamai.net/7/123/11558/abc123/forestservic... · 2014-07-16 · Guidance for Vegetation

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FOREST SERVICE NATIONAL DESK GUIDE

TO PREPARING

VEGETATION MANAGEMENT PROCEDURES

FOR

POWER LINE AUTHORIZATIONS

December 20, 2013

CONTENTS

I. Purpose

II. Operating Plans and Vegetation Management Procedures

III. Vegetation Clearing Procedures

IV. Environmental Compliance

V. Stumpage Payments

VI. Fuels Treatment

VII. Coordination and Communication

VIII. Cost Recovery

Appendix A – Definitions

Appendix B – Guidance for Vegetation Management Procedures

Appendix C – General Procedures for Biological Assessments and Evaluations

Appendix D – General Procedures for Cultural Resource Clearances

Appendix E – Background on Industry-Preferred Underwire Vegetation Management

Appendix F – Considerations for Negotiating Clearing Procedures

Appendix G – Timber Management Guidance for Utility Line Maintenance

Guidance for Vegetation Management Procedures for Power Line Authorizations

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I. PURPOSE This desk guide is designed to provide consistent guidance to Forest Service staff in helping holders of a special use authorization for a power line (utilities) develop comprehensive vegetation management procedures and to provide consistent guidance to Agency staff in reviewing and approving vegetation management procedures. The central purpose of vegetation management is to help ensure that public energy needs are reliably served without interruption from vegetation interference, while also ensuring people, wildlife, property, and lands are not harmed or threatened by wildfire caused by trees on power lines and other power-line related fires. This guidance for vegetation management coincides with the multi-agency Edison Electric Institute (EEI) Memorandum of Understanding (MOU). The EEI MOU establishes an understanding among the signatories of the mutually beneficial necessity to efficiently manage vegetation in and around power line rights-of-way to ensure safe, reliable, and secure electrical service to the public. This desk guide provides guidance. It does not impose strict requirements for maintaining vegetation within a specific power line right-of-way. The applicability of this guidance may vary according to site-specific circumstances. It is impossible to create one set of vegetation management procedures for all landscapes. However, having agreed-upon guidance for managing vegetation within transmission and distribution rights-of-way (ROWs) across National Forest System (NFS) lands helps provide a degree of consistency to Agency staff and utilities in planning and conducting vegetation management. This consistency supports the delivery of safe, reliable electricity to the public while protecting NFS lands and other important natural resources. Terms of art used in this desk guide are defined in Appendix A. II. OPERATING PLANS AND VEGETATION MANAGEMENT PROCEDURES To provide a dependable supply of electricity, utilities must manage vegetation near their transmission and distribution lines and other facilities to prevent blackouts and wildfires, which can harm people, property, wildlife, habitat, and natural and cultural resources. Properly managed vegetation can also reduce the risk of wildfire damage to utilities’ infrastructure. An operating plan attached to a special use authorization is the Agency tool for granting utilities permission to perform required vegetation maintenance. The operating plan should cover all operations authorized by the special use authorization. The operating plan should outline steps the holder will take to protect public health and safety and the environment. At a minimum, the operating plan should address access to and operation and maintenance of the power line facilities, including dates or season of operations; activities and procedures to prevent and control the spread of invasive species; vegetation management procedures; any plan for pesticide use; and restrictions on use, such as fire restrictions, established by the Forest Service. Each


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operating plan is specific to the power line and land on which the power line is sited. A sample operating plan is available at http://wwwtest.fs.fed.us/specialuses/documents/2007%20Lolo-NWE%20row%20mgt.plan.pdf. The vegetation management procedures should enumerate criteria and methods for removal, destruction, and trimming of vegetation that are in conformance with generally accepted practices for vegetation management. In addition, the vegetation management procedures should provide for integration of native, non-invasive vegetation that does not interfere with the transmission facilities and that promotes their reliability, reduces their maintenance costs, and is compatible with the aesthetics and health of the native plant and animal life in the permit area. Operating plans should address vegetation management for at least one full operating season, as well as access and non-emergency and emergency operations. The authorized officer and utility should discuss the operating plan annually and prior to non-emergency vegetation management to ensure that the operating plan satisfies Agency and utility needs and that the work can be done safely under current conditions. Power line authorization holders should submit plans for scheduled vegetation maintenance to the authorized officer. Notification should be sent far enough in advance of anticipated work to allow time for appropriate Agency review of the operating plan, planned work, and current conditions that might impact or be impacted by the vegetation maintenance, such heightened fire conditions or other work. Increased notification time and prompt Agency review allows the utility to shift planned work from one location to another based on identified limiting factors. See Appendix B for additional guidance on developing vegetation management procedures. IV. VEGETATION CLEARING PROCEDURES Ongoing Management and Imminent Threats Distance between power lines and vegetation needs to be maintained to prevent vegetation from touching lines with or without the influence of wind and to prevent arcing. Under Section 215 of the Federal Power Act, as amended by the Energy Policy Act of 2005, the Forest Service is required, in accordance with applicable law, to expedite Agency approvals that are necessary to allow utilities to comply with any reliability standard approved by the Federal Energy Regulatory Commission (FERC) that pertains to vegetation management or resolution of situations that imminently endanger the reliability or safety of electric transmission facilities. 16 U.S.C. 824o note. Consistent with this provision, the typical electric transmission line easement and permit stipulates that Forest Service authorization of a transmission line will include approval of vegetation management procedures as part of the operating plan. The vegetation management procedures must enumerate criteria and methods for removal, destruction, and trimming of vegetation that are in conformance with generally accepted practices for vegetation management. In addition, the vegetation management procedures should provide for integration of native, non-

http://wwwtest.fs.fed.us/specialuses/documents/2007%20Lolo-NWE%20row%20mgt.plan.pdf

http://wwwtest.fs.fed.us/specialuses/documents/2007%20Lolo-NWE%20row%20mgt.plan.pdf


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invasive vegetation that does not interfere with the transmission facilities and that promotes their reliability, reduces their maintenance costs, and is compatible with the aesthetics and health of the native plant and animal life in the permit area. Also consistent with Section 215 of the Federal Power Act, the typical electric transmission line easement and permit provide for non-emergency and emergency removal of vegetation. Non-emergency vegetation management is vegetation operations that require prior coordination with the authorized officer or legal surrogate. In emergency situations, i.e., when there is hazardous vegetation threatening the integrity of the transmission line, the utility may remove, destroy, or trim the vegetation inside or outside the authorized ROW, as needed to protect the transmission line, without prior approval. In either case, vegetation is removed in accordance with the utility’s vegetation management procedures. Vegetation Clearing The frequency, methods, and scope of vegetation clearing are driven by the characteristics of the power lines, support structures, land features, and plans governing management of the land and related natural and resources. Utilities are moving away from simply clearing all trees and tall shrubs within the authorized ROW to a combination of cutting and cultural practices called Integrated Vegetation Management (IVM). Through IVM, tall vegetation is replaced with vegetation that require less frequent clearing and may provide other benefits, such as reduced fuels loading. One example of an IVM approach is the wire zone/border zone concept as explained in Appendix E. Clearing needs can vary over the length of a power line. For example, it may be appropriate to apply a broad IVM approach (such as the wire zone/border zone concept) except in locations where other overriding Agency resource objectives require different vegetative cover. The authorized officer may accept the utility-preferred vegetation management practice, but the authorized officer may also specify other approaches where there are documented resource-related reasons for doing otherwise. That documentation could take many forms, such as Forest or Grassland plans and guidance for specific circumstances, including preservation of visual quality, preservation of cultural resources, or wildlife habitat conservation measures resulting from an ESA consultation with the U.S. Fish and Wildlife Service (FWS) or National Marine Fisheries Service (NMFS). Clearing procedures for a power line, including clearances needed for support structures, should be documented in the operating plan attached to and incorporated into the authorization. Once clearance procedures are finalized, they apply throughout the term of the operating plan, unless the parties mutually agree otherwise, or there are new requirements of law or regulation that affect clearing procedures. The authorized officer may unilaterally apply new procedures that are mandated by a law or regulation after consulting with the utility. Other proposed changes to a previously approved operating plan, especially to clearing procedures, must be approved by the authorized officer.


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Utilities are required by the North American Electric Reliability Council (NERC) to prepare and keep current a transmission vegetation management program (TVMP). NERC functions as an electric reliability organization (ERO) under FERC’s regulatory control as specified by the Energy Policy Act of 2005. The TVMP is a formal document that utilities use to manage vegetation to achieve NERC standards. In particular, the TVMP establishes guidance used by utilities to plan and perform vegetation management that is necessary to prevent transmission outages and minimize risk to the transmission system. Forest Service vegetation management guidance has taken into consideration NERC standards utilities must meet. Furthermore, where specific NERC standards exist, based on the project or landscape, utilities can seek to incorporate those standards into Forest Service-approved vegetation management procedures. Although NERC standards do not supersede laws, regulations, and directives governing Forest Service management of NFS lands, Agency staff should understand regulatory standards that apply to utilities and seek to find common ground on issues pertaining to management of utility ROWs on NFS lands. The following are significant considerations, per NERC standards, for utilities conducting vegetation management:

A. Underwire Clearing Standards for Power Lines

1. Utility-Preferred Clearing Standards

The utility-preferred standard is usually some form of IVM, such as the wire zone/border zone concept shown in Appendix E, Figure 2. The authorized officer’s acceptance of the industry-preferred standard and the segments of a line to which that standard will apply should be documented in the operating plan. Vegetation management procedures in the operating plan will apply only to the corresponding authorized ROW. Changes in the width of the authorized ROW must be approved through the process described in section III.A.2.

2. Considerations for Approval of Vegetation Management Procedures

At a minimum, discussions regarding vegetation management procedures should consider industry minimum clearing standards (see Appendices E and F), line sag allowances, vegetation growth rates as related to reasonable maintenance cycles, and horizontal spacing for residual vegetation. Sources of numeric wire clearance standards include the National Electric Safety Code (NESC) and the Institute of Electrical and Electronic Engineers (IEEE). These safety standards specify clearances between conductors (lines) and workers, tools, or vegetation. These safety standards reflect normal operating conditions and do not account for factors such as humidity and particulates in the air, which can increase the arcing potential.


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Of particular concern to industry is vegetation around and under the center line sag zone. This area has the greatest potential for arcing during periods of heavy loads, which usually occur at the peak of the fire season. Maintaining minimum clearing requirements under those conditions often requires removing all of the taller-growing vegetation in the center span zone. When assessing resource issues and discussing clearing requirements for this zone (see Appendix F, Figure 3), where practicable, the authorized officer should seek to identify mitigation measures outside the center span zone to avoid conflicts with clearing requirements for that zone. There may be opportunities to retain vegetation in the center span zone where topographical variations such as canyons or drainages create more distance between ground level and the lines than would normally exist. The actual area of the center span zone that will be maintained to the IVM-based general standard will be negotiated between the parties. The underwire areas in which the parties will typically be negotiating to leave vegetation for resource-related reasons are shown in Appendix F, Figure 3, as lateral zones. The NESC or IEEE clearance standards do not account for line sag. These standards specify only how much clearance should exist at the time clearance is measured. Line sag could be minimal when the clearance is measured under low-voltage load conditions and with low ambient air temperatures. However, in the summer and under heavier voltage loads, some lines will sag considerably. The final negotiated minimum clearance requirements need to account for maximum sag conditions. Other factors affecting clearances include the anticipated growth rate of vegetation and the anticipated duration of the treatment cycle. Predictions of vegetation growth rates and the treatment cycle need to be combined with the other factors mentioned previously to assure that clearances will remain acceptable over the term of the special use authorization. In general, a reasonable starting point for discussing a cycle for periodic maintenance is five years. The five-year period was identified as the industry norm in the September 7, 2004, FERC report to Congress – Utility Vegetation Management and Bulk Electric Reliability Report from the Federal Energy Regulatory Commission. In that report, FERC recommended shorter cycles for improved reliability. Action taken at the beginning of the cycle should allow for expected vegetation growth so that additional maintenance would not be needed until the end of the cycle. Longer or shorter cycles may be considered as warranted by vegetation conditions near facilities.

When vegetation is left under the lines for resource-related reasons, horizontal spacing of residual vegetation may need to accommodate mechanical access needs or minimize a fire hazard. If the use of mechanical thinning equipment is requested by the utility, the authorized officer should consider horizontal spacing necessary for use of that equipment, balanced against resource needs and alternative treatment options. Fire crowning and torching potential for the residual vegetation may or may not be an issue depending on


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local conditions, especially the nature of vegetation adjacent to the authorized ROW. Vegetation spacing should be addressed on a site-specific basis, and spacing requirements should be developed with involvement of local fuels management and other specialists (e.g., a wildlife biologist, silviculturist, and ecologist), as appropriate. The final horizontal and vertical clearance requirements for any given section of the power line should be discussed on the ground by appropriate representatives of each party and should be documented within the vegetation management procedures. Any changes to clearing procedures already approved in the operating plan must be approved by the authorized officer, following NEPA analysis and any other necessary procedures, such as ESA consultation. If the utility disagrees with the authorized officer, the utility should attempt to resolve the dispute through the next line officer in the chain of authority (district ranger, forest supervisor, regional forester, Forest Service chief).

B. Hazardous Vegetation Vegetation that could potentially threaten power lines should be removed during periodic maintenance. However, some vegetation grows at rates that require the utility to perform unscheduled maintenance. The guidance for identifying hazardous vegetation and communicating the need and process for removing this vegetation should be clearly described in the operating plan. A definition for hazardous vegetation is included in Appendix A.

C. Clearing Requirements for Support Structures

The NESC standard for minimum clearances around support structures and associated guy lines is 50 feet. The extent of clearing necessary within this area may vary. Some additional leeway may be needed to expand clearances to account for factors such as susceptibility of structures to wildland fire due to slope position. Figure 1 shows the desired result from clearing around a support structure with a guy line. If the area of proposed clearance exceeds the project ROW, see section IV for guidance on vegetation management beyond the authorized ROW.


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Figure 1

D. Designation of Vegetation to Be Removed

Except in cases of emergency removal of vegetation, commercial wood products will be designated according to the guidance in Appendix G. The process for approving non-emergency removal of other vegetation should be described in the operating plan.


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IV. ENVIRONMENTAL COMPLIANCE Utility authorizations are subject to all applicable federal laws, regulations, and agency directives. This section addresses some of the major environmental laws that apply: the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and the NHPA. The ESA and NHPA may require surveys, which are collectively referred to as “resource surveys.” This section does not delineate all legal requirements associated with these environmental laws. Contact the local Office of the General Counsel regarding specific questions pertaining to legal requirements.

A. NEPA Compliance for Vegetation Management The need for NEPA analysis in response to proposed vegetation management will depend on whether it is already allowed under the terms of the authorization. Operating plans can specify which vegetation treatments are authorized and whether they require notice before or after application and which might require additional environmental analysis and Agency approval. Activities permitted under an authorization, including emergency and non-emergency vegetation management, usually may continue without new NEPA analysis, provided that no new decision is required from the Forest Service. If the proposed activity is not within the scope of the existing authorization, a new decision subject to NEPA analysis could be required.

Non-emergency vegetation management outside the scope of an authorized ROW requires a new decision subject to the Forest Service’s NEPA procedures (36 CFR Part 220, FSM 1950, FSH 1909.15. Additional NEPA analysis will inform whether the authorized officer issues a new or amended easement or permit with an expanded ROW.

B. Resource Surveys If resource surveys were not performed before a project was initially authorized, surveys may be required to support new ground-disturbing operations. New information or changed circumstances, such as a newly listed threatened or endangered species, might also trigger additional resource surveys. The results of the resource surveys could indicate the need for restrictions on vegetation management, such as scheduling constraints, to protect threatened or endangered species or critical wildlife habitat. It is also possible that resource surveys were performed for initial construction of a power line, but not for vegetation management of the ROW. In that case, the Agency should review the full range of proposed vegetation management to determine if additional resource surveys are warranted.


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C. Biological Assessments and Evaluations (BA/BEs) The objectives of a BA/BE are to identify the effects on threatened or endangered species and habitat, identify measures to minimize those effects, expedite the process for acquiring needed clearances, and minimize financial and other impacts on all parties. The most efficient means of pursuing a BA/BE is to evaluate the largest reasonable area of impact that can be assessed thoroughly and for which the effects can be comprehensively displayed. Looking at larger areas and lengthier time periods makes it possible to be more thorough in identifying short-term, long-term, and cumulative effects. Additional discussions may be needed after ESA consultation to adjust for other Agency concerns unrelated to habitat management. See Appendix D for background on developing the BA/BE. D. NHPA Compliance The objectives of a cultural resource clearance are to identify historic properties within the project’s area of potential effect, evaluate the effects of the undertaking on historic properties, and identify measures to avoid or mitigate adverse effects. This process involves consultation with affected tribes, the State Historic Preservation Officer, and other consulting parties under the NHPA. In some cases, a programmatic agreement may be an efficient and effective way for the Agency to meet its responsibilities under the NHPA in an expedited manner. Forest Service regulations implementing NHPA are found at 36 CFR Part 800.

V. STUMPAGE PAYMENTS Decisions to charge for timber and other forest products should be guided by regulations at 36 CFR 223.12 and timber settlement policy at FSM 2464. The most likely end product (saw timber versus fuels wood, for example) should be used to determine commercial value. Even if the authorized officer does not charge stumpage rates for timber of merchantable size and quality, the authorized officer may assess other timber-related charges, including road maintenance deposits and damage rates (see Appendix G). When wood products are sold separately, the authorized officer may have the material decked by the utility for sale, with no charge to the utility for the wood products. There are situations where commercial wood products can be left on site without payment (see Appendix G and FSM 2464.12.) See Appendix G for guidance on designation of trees to be cut and other timber preparation actions to be taken. Utilities are not expected to have marked for removal of any non-merchantable trees smaller than the minimum specified diameter. The authorized officer generally will calculate the volume and value of timber to be removed.


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VI. FUELS TREATMENT The authorized officer and utility should make every effort to coordinate vegetation management with other fuels treatment in adjacent areas such as wildland-urban interface (WUI) projects. Utilities are responsible for the cost of fuels treatment related to operations within their authorized ROW. Utilities are also responsible for emergency removal of hazardous vegetation outside the authorized ROW that poses an imminent threat to their lines by falling onto the lines or creating electrical arcs. To avoid these situations, it may be mutually beneficial for the Agency and utilities to enter into a cooperative agreement such as a collection agreement to mitigate potential fires by removing fuels that could ignite inside or outside the ROW. The required treatment of slash or wood products left on site should be reasonably cost-efficient for the utility. The results of fuels treatment must be acceptable to the Agency and must not increase the risk of fire and should be reasonably cost-efficient for the utility. Deck locations for logs and other timber products must be approved in advance by the authorized officer. Consideration should be given to the length of time decks may remain on site and the potential hazard that smoke from burning decks could pose to personnel during fire suppression activity near the power lines. VII. COORDINATION AND COMMUNICATION

A. Contact Information, Description of Duties, and Delegation of Authority When vegetation management procedures involve extensive areas, coordination and communication can be critical. In these situations, the authorized officer and utility should each designate points of contact (coordinators), along with a general description of the coordinators’ duties, geographic area of responsibility, and delegation of authority. Coordinators should be able to communicate and coordinate effectively with individuals inside and outside their organizations who are involved with the power line. The Agency coordinator should be on the staff responsible for administration of the special use authorization for the power line. The delegation of authority to the Agency coordinator should identify the name and title of the person who has authority to make decisions in connection with the power line and the name and title of the coordinator’s immediate supervisor. The coordinator’s contact information should be included in the operating plan. The Agency coordinators’ duties may include: 1. Communicating requirements of laws, standards, policies, and procedures governing

Agency operations to achieve land management planning goals, objectives, and desired conditions.

2. Clarifying requirements of operating plans (including vegetation management procedures) and construction plans that apply in the designated geographic area.


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3. Arranging resource surveys if needed.

4. Acquiring specialist input on adjustments needed to address local issues and conditions and to identify potential mitigation. Situations where specialist input may be needed include the:

a. Need for review of seeding and planting recommendations.

b. Potential for soil erosion due to reduction of vegetative cover.

c. Potential presence of endangered or threatened animal and plant species.

d. Need to limit or mitigate indirect effects of a ROW corridor, e.g., recreational vehicle use.

5. Arranging meetings with Agency staff and the utility. The Agency coordinator should gather key staff from each affected ranger district and the supervisor’s office at a single, unit-wide meeting unless otherwise agreed to by the Agency and the utility. The Agency coordinator should attend all meetings, unless otherwise agreed to by the Agency and the utility, and should follow up as necessary on behalf of the authorized officer.

6. Distributing appropriate information from the coordinator’s counterpart to all affected Forest Service subunits in the designated geographic area.

7. Communicating with line officers and specialists periodically to apprise them of issues and concerns that may arise and to inquire about new information or changed conditions that may affect management of the ROW corridor.

8. Coordinating the preparation of any necessary correspondence to the coordinator’s

counterpart regarding administration of the special use authorization for the ROW.

9. Resolving inconsistency between subunits and disputes with the coordinator’s counterpart.

10. Addressing any safety concerns associated with removing vegetation, such as ensuring utilities are aware of any increased fire risk and the need for spark arrestors and other fire suppression equipment during maintenance operations.

B. Lead Unit Coordinator When a transmission line affects multiple administrative units (Ranger Districts or National Forests), the Forest Supervisor or the Regional Forester may designate a lead administrative unit to coordinate with the utility. Usually, the administrative unit that is impacted the most is designated as the lead administrative unit, and a coordinator is designated for that unit (lead unit coordinator). Duties of the lead unit coordinator parallel those outlined for


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coordinators in section VII.A. The lead unit coordinator should work through any other Agency coordinators involved in management of the ROW corridor.

C. Informal Dispute Resolution Typically, utilities may request to discuss their concerns through the chain of line officers responsible for management of the land covered by the power line ROW.

VIII. COST RECOVERY Under the Forest Service’s cost recovery regulations and directives (36 CFR 251.58 and FSH 2709.11, Ch. 20), applicants for a special use authorization for a ROW are subject to fees for costs incurred by the Agency that are necessary for processing their application, including Agency costs incurred in approving an operating plan and resource surveys, associated environmental analysis conducted by the Agency, and ESA consultation needed to process an application. Holders of a special use authorization for a ROW are also subject to fees for costs incurred by the Agency in monitoring compliance with the terms and conditions of their special use authorization. A Category 5 Master Agreement or Category 6 Agreement may be appropriate for cost recovery associated with anticipated expansion, monitoring, or maintenance of a power line ROW, particularly where compliance with NEPA, ESA, NHPA, or other environmental laws is required. See 36 CFR 251.58 and FSH 2709.11, chapter 20, for cost recovery requirements.


Appendix A – Page 1

APPENDIX A

Definitions

Arcing – The flow of electricity across a gap through the air from one conductor to another or to a grounded object. Authorized Officer – Any employee of the Forest Service who has the delegated authority to perform the duties described in 36 CFR Part 251 and who has been so designated in a special use authorization. Corridor – For purposes of this desk guide only, an area of land, often without fixed limits or boundaries, which is designated in a land management plan as the preferred location for potential utility ROWs. Defect – An injury, disease, or condition that significantly weakens the stems, roots, or branches of a tree or vegetation, predisposing part or all of the plant to fail and fall toward a power line facility. Emergency Removal – Removal in accordance with the applicable vegetation management procedures of trees, shrubs, grasses, or other plants without having them marked by the authorized officer when they have compromised or threaten to compromise a power line and there has been loss of power or loss of power is imminent. Hazardous Vegetation – An alive or dead standing tree or other plant having one or more defects, singly or combined, in the roots, butt, bole, or limbs, including arcing potential, that predispose it to cause imminent mechanical failure to the whole or part of a power line, pole, or tower. Line Sag – The situation that occurs when a power line stretches due to voltage loading, external temperature, or both and moves closer to the ground and underlying vegetation. Operating Plan – A written plan that is prepared by the holder of a special use authorization in cooperation with the authorized officer, approved by the authorized officer, and incorporated into the special use authorization as an attachment and that documents approved procedures for operating the authorized facilities. Non-Emergency Removal – Periodic or routine maintenance that is scheduled to maintain general vegetation clearances from power lines. Special Use Authorization – A permit, term permit, lease, or easement which allows occupancy, use, rights, or privileges of NFS lands. Span – A segment of power line between two support structures.


Appendix A – Page 2

Vegetation Clearing Standards – For purposes of this desk guide only, performance measures for vegetation maintenance that are developed in one or more of the following ways:

1. By a national institution that has developed standards that are widely accepted as the industry norm, such as the NESC or IEEE.

2. By a regulatory agency such as FERC that has been granted authority to establish reliability standards under the Energy Policy Act of 2005.

3. By agreement of the Agency and special use authorization holder. Vegetation Management Procedures – A part of the operating plan that explains the criteria and methods for removal, destruction, and trimming of vegetation that are in conformance with generally accepted practices for vegetation management.


Appendix B – Page 1

APPENDIX B

Guidance for Vegetation Management Procedures A. Introduction The general concept of vegetation management is discussed in section II of the desk guide. This appendix provides more detail on the subject. B. Components Vegetation management procedures can be organized in any manner necessary to fit the situation. Three general sections are suggested: an introduction, operating procedures, and natural and cultural resource compliance requirements.

1. Introduction

The introduction should contain: a. A description of the general purpose of vegetation management, which is to control

vegetation near the authorized power line and additional facilities to prevent blackouts and wildfires.

b. Actions that will take place on the ground.

c. Vegetation management objectives from the applicable land management plan.

2. Operating Procedures

The operating procedures should include: a. A description of intended treatment results, including clearing plans, a specified

proposed treatment cycle so that the Agency can determine the effects of proposed treatment at every location, and a description of how vegetation other than commercial wood products will be removed.

b. A description of approved treatment methods, types of equipment, and timing of applications.

c. Identification of areas requiring special treatment due to resource values.

d. Methods to be used for designation of and payment for commercial wood products. e. A description of proposed slash treatment, including timing of applications.


Appendix B – Page 2

f. A description of the access routes to be used. g. A description of any ancillary agreements, such as collection agreements, related to

vegetation management.

h. A description of how hazardous vegetation inside and outside the authorized ROW will be handled.

i. Specification of responsibility for safety, fire hazard, and reliability monitoring and

inspections and their frequency (FSM 2716.5).

j. Plans for implementing any required mitigation in the decision document for the authorized ROW.

k. Identification of reliable remote communications and contact information for the

nearest fire station.

3. Natural and Cultural Resource Compliance Requirements

The vegetation management procedures should contain applicable natural and cultural resource considerations from the following documents:

a. The BA/BE and, if necessary, biological opinion and any migratory bird report for the

authorized ROW.

b. The archaeological survey and NHPA compliance documentation.

c. Any other specialist reports that were developed to address issues identified during the initial or subsequent NEPA analysis, such as a landscape architect’s report on visual quality, an invasive species report, a fuels analysis, or a memorandum of agreement for the resolution of adverse effects under NHPA.


Appendix C – Page 1

APPENDIX C

Procedures for BA/BEs

A. Contact designated environmental coordinators. B. Discuss the following items during strategy formulation: Each of these items may require initial contacts with the designated coordinator for background information.

1. The location and timing for immediate and future needs for maintenance and reissuance of the special use authorization. Consolidate these tasks when possible for efficiency.

2. Jurisdiction of affected lands. 3. Applicability of any existing memoranda of understanding among agencies. 4. A determination of whether maintenance is covered under the current NEPA analysis or

whether revised or additional NEPA analysis is needed. 5. Existing BAs/BEs and an assessment of whether they meet current requirements. 6. A determination of whether resource surveys are needed, and if so:

a. The type and extent of the surveys; b. Timeframes for completion of the surveys (in some cases, they take up to 2 years to

complete); c. Estimated cost of conducting the surveys; d. Availability of resources to complete the surveys in a timely manner; e. Issuance of a current special use permit for any contractor used by the utility to

conduct the surveys; and f. The most efficient and consistent approach (e.g., single or multiple administrative

units or multiple agencies). 7. Identification of threatened or endangered species that could be affected and specific

locations within the ROW where they would be a concern.

8. Assess the value of planned vegetation clearing in decreasing risk of excessive damage by wildfire, increasing the resiliency of wildlife habitat, improving conditions for native plants, and restoring and maintaining native forest communities.


Appendix C – Page 2

C. Implement the strategy.

1. Based on the results of these discussions, assess whether it would be more efficient to

prepare one or several BA/BEs to expedite processing for minimally impacted areas. 2. If appropriate, adopt mitigation measures, such as restricting the timing of specific

actions, to minimize adverse effects.

D. If the utility volunteers to provide an evaluation to obtain more timely clearances or to reduce Agency costs subject to cost recovery, discuss the following to assure complete understanding of expectations:

• The type and format of documentation that will be prepared to record the agreement.

BAs should follow the outline recommended by FWS or NMFS

• Qualifications and availability of personnel to do the work, regardless of whether they are utility employees or contractors.

• Where appropriate, programmatic consultations to enhance efficiency. Assure that the Forest Service and FWS or NMFS agree on the meaning of key terminology.

• The timeframe needed by the utility to implement the proposed actions and the timeframe needed by the Agency to review and approve the documentation provided by the utility.

• The expected timeframe for consultation with FWS or NMFS, which varies greatly based on whether there are threatened or endangered species present and the potential impacts on those species.


Appendix D – Page 2

APPENDIX D

General Procedures for Cultural Resource Clearances

A. Contact designated coordinators. These contacts need to be made as far in advance as possible. B. Discuss the following items during strategy formulation: Each of these items may require initial contacts with the designated coordinator for background information.

1. The location and timing for immediate and future needs for maintenance and reissuance of the special use authorization. Consolidate these tasks when possible for efficiency.

2. Jurisdiction of affected lands. 3. Applicability of any existing memoranda of understanding, memoranda of agreement,

interagency agreements, or programmatic agreements among agencies. 4. A determination of whether maintenance is covered under the current NEPA analysis or

whether revised or additional NEPA analysis is needed. 5. A determination of whether maintenance is covered under any current NHPA compliance

documentation or whether revised or additional NHPA analysis and consultation are needed.

6. A determination of whether existing cultural resource surveys are adequate and meet

current clearance plans, and whether existing clearances cover the proposed ROW or whether resource surveys are needed. If resource surveys are needed, address the following:

a. The type and extent of the surveys; b. Timeframes for completion of the surveys (in some cases, they can take up to 2 years

to complete); c. Estimated cost of conducting the surveys; d. Availability of resources to complete the surveys in a timely manner; e. Issuance of a current special use permit for any contractor used by the utility to

conduct the surveys; and


Appendix D – Page 2

f. The most efficient and consistent approach (e.g., single or multiple administrative units or multiple agencies).

C. Implement the strategy.

1. Based on review of existing records and the results of the surveys, identify cultural

resources that could be affected by the proposed ROW and any specific locations within the ROW where cultural resources would be a concern.

2. If appropriate, adopt mitigation measures to minimize adverse effects. Develop a memorandum of agreement to address adverse effects in consultation with the State Historic Preservation Office (SHPO), Advisory Council on Historic Preservation, and affected tribes. 3. Section 106 compliance must be completed prior to signing the NEPA decision.

C. If the utility volunteers to obtain more timely clearances or to reduce Agency costs

subject to cost recovery, discuss the following to assure complete understanding of expectations:

• The type and format of documentation that will be prepared to record the agreement.

• Qualifications and availability of personnel to do the work, regardless of whether they are

utility employees or contractors.

• Where appropriate, programmatic consultations to enhance efficiency.

• The timeframe needed by the utility to implement the proposed actions and the timeframe needed by the Agency to approve the documentation provided by the utility.

• The expected timeframe for the Agency to complete consultation with the SHPO, affected tribes, and Advisory Council on Historic Preservation, which varies greatly based on whether there are historic properties present and the potential impacts on those resources.


Appendix E – Page 1

APPENDIX E

Background on Industry-Preferred Underwire Vegetation Management

Long-Term Management Strategy: IVM The industry-preferred long-term vegetation management strategy for electric utility ROWs is IVM. IVM is the practice of creating and maintaining low-growing herbaceous and woody plant communities. The desired outcome of IVM is to convert the site to stable shrub, grass, and forb (low-growing) plant communities that do not interfere with overhead power lines, pose a fire hazard, or hamper access. Over time, IVM can reduce the frequency and magnitude of vegetation management activities. Wire Zone/Border Zone Concept The wire zone/border zone concept is one approach to IVM. The wire zone/border zone concept is based on the State Game Lands 33 Research and Demonstration Project (often called the Bramble and Byrnes Study),∗ which was initiated in 1952 in an eastern deciduous forest. The Bramble and Byrnes Study is the longest-lasting continuous assessment (spanning more than 50 years) of the effects of utility vegetation management on wildlife and plants along an electric transmission ROW.

Figure 2 ∗ Yahner, Richard H. “Wildlife Response to More than 50 Years of Vegetation Maintenance on a Pennsylvania, U.S., Right-of-Way.” Journal of Arboriculture 3(20):123-126. March 2004.

Wire Zone/Border Zone Concept



As shown in Figure 2, the wire zone/border zone concept divides the underwire area into two sections: the wire zone (the area directly under the power lines) and the border zone (a transition zone that fringes each side of the wire zone). The ideal wire zone is composed of grass, forbs, and low shrubs bordered by low-to-medium-sized shrubs in the border zone. Low-growing trees account for the outer edge of the ROW, where the border zone meets the natural forest. In addition to developing vegetation that is more desirable from an industry perspective, managing vegetation according to the wire zone/border zone concept provides conditions that may be beneficial to wildlife. As discussed in section V of the desk guide, there may be situations where the Forest Service requires alternative vegetation management in response to site-specific resource needs, such as visual quality or riparian and fisheries habitat. Key Standards for Vegetation Management American National Standards Institute (ANSI) A300. Tree Care Operations – Tree, Shrub and Other Woody Plant Maintenance – Standard Practices (2001) (revision and redesignation of ANSI A300, 1995) (includes supplements). American National Standards Institute, 1819 L Street, NW, 6th floor, Washington, DC 20036, 202-293-8020, http://www.ansi.com. ANSI Z133.1. American National Standard for Tree Care Operations--Pruning, Trimming, Repairing, Maintaining, and Removing Trees, and Cutting Brush-Safety Requirements (1994). American National Standards Institute, 1819 L Street, NW, 6th floor, Washington, DC 20036, 202-293-8020, http://www.ansi.com. IEEE Standard 516-2003. Guide for Maintenance Methods on Energized Power Lines, Institute of Electrical and Electronics Engineers, New York, NY, 20003. ISBN: 0-7381-3569-0.

NERC Reliability Standards

• NERC is a nonprofit New Jersey corporation whose members are ten regional reliability councils. The members of these councils come from all segments of the electric industry: investor-owned utilities; Federal power agencies; rural electric cooperatives; state, municipal, and provincial utilities; independent power producers; power marketers; and end-use customers. These entities account for virtually all the electricity supplied and used in the United States, Canada, and a portion of Baja California Norte, Mexico.

• NERC’s function is to maintain and improve the reliability of the North American

integrated electric transmission system. This includes preventing outages from vegetation located within transmission ROWs, minimizing outages from vegetation adjacent to ROWs, maintaining clearances between transmission lines and vegetation within and adjacent to transmission ROWs, and reporting vegetation-related outages of the transmission systems to the respective Regional Reliability Organizations and NERC.

http://www.ansi.com/

http://www.ansi.com/



• Under section 1211 of the Energy Policy Act of 2005, NERC reliability standards are binding and enforceable on utilities and are overseen by FERC.

• Electric utilities are required to have a procedure for managing vegetation in place per

NERC Standard FAC-003-02, which will become effective in July 2014. http://www.nerc.com/docs/standards/sar/FAC-003-2_Technical_White_Paper_2008Oct22.pdf.

• Clapp, Allen L. NESC Handbook: Development and Application of the American National Standard, National Electrical Safety Code Grounding Rules, General Rules, and Parts 1, 2, and 3 by Allen L. Clapp. 1984. Institute of Electrical and Electronics Engineers, 1984, New York, NY, 430 p.: ill.; 20 cm. ISBN: 0471807834.

• The NESC is the national code covering basic provisions for safeguarding persons from

hazards resulting from installation, operation, and maintenance of conductors and equipment in electric supply stations, overhead, and underground electric supply and communication lines.

• The NESC also contains rules governing construction, maintenance, and operation of

electric supply and communication lines and equipment.

http://www.nerc.com/docs/standards/sar/FAC-003-2_Technical_White_Paper_2008Oct22.pdf

http://www.nerc.com/docs/standards/sar/FAC-003-2_Technical_White_Paper_2008Oct22.pdf



Occupational Safety and Health Administration (OSHA) Standard 29 CFR 1910.269

● OSHA standard 1910.269 applies to line clearance and tree trimming operations performed by qualified employees (those who have knowledge of the construction and operation of electric power generation, transmission, and distribution equipment and their associated hazards). These employees typically perform tree-trimming as an incidental part of their work.

Uniform Fire Code (UFC)™, 2003 Edition, National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02269

• This code covers hazards from fires in vegetation, trash, building debris, and other materials.

Urban-Wildland Interface Code (UIC), 2003 International Edition

● The UIC establishes methods and timetables for controlling, changing, and modifying property at the interface between developed and undeveloped areas.

● Methods include removal of slash, snags, and vegetation that come in contact with electrical lines. Additional methods include removal or thinning of ground or ladder fuels and dead trees.


Appendix F – Page 1

APPENDIX F

Considerations for Negotiating Clearing Procedures

As explained in detail in the desk guide, the utility and authorized officer will discuss clearance procedures in situations where Agency resource management concerns preclude use of the wire zone/border zone concept as the underwire clearance standard. Section V of the desk guide discusses the factors that should be addressed during the negotiations. Figure 3 below illustrates the portions of the ROW subject to the negotiations, known as the lateral zones.

Figure 3

As shown by Figure 3, there may be opportunities to retain additional vegetation under the line segments between the outer limits of the center sag zone and the support structures. As noted in the desk guide, the center sag zone would normally be managed under the wire zone/border zone concept. The reference to the “border zone” in the schematic refers to the wire zone/border zone concept from Appendix E. Additional opportunities to retain vegetation may also occur where


Appendix F – Page 2

topographical features such as canyons or deeper drainages create more vertical separation between ground and/or treetop level and the power lines. The length of the vegetation management cycle may also be negotiated. Factors to consider include the need to maintain taller vegetation for site-specific resource management (for example, riparian habitat or visual quality) requiring shorter entry cycles, balanced against reliability, practicality, and cost-efficiency afforded the utility by longer vegetation management cycles. In its September 7, 2004, report to Congress, FERC noted that five years was the industry norm for vegetation management cycles and recommended shorter cycles for improved reliability. Certain minimum clearances should always be observed, based on national standards for arcing potential. These minimum values do not account for line sag or vegetation growth during the vegetation management cycle. The parties will have to consider those factors during discussions for site-specific needs. Nationally, utilities’ vegetation management practices are guided by NERC Standard FAC-003 for Transmission Vegetation Management Programs and ANSI A300, Integrated Vegetation Management ̶ Part 7, which provide guidance for vegetation management of utility ROWs. Both standards outline strategic approaches for vegetation management within transmission ROWs that will allow utilities to maintain reliable electric transmission systems and minimize encroachments from vegetation located adjacent to the ROW, reducing the risk of vegetation-related outages that could lead to service interruption and wildfires. These standards can be found or purchased online. Utilities referencing these documents as part of their request to perform vegetation management should provide copies to Agency staff.


Appendix G – Page 1

APPENDIX G

Timber Removal Guidance for Utility Line Maintenance

A. Tree Designation and Removal An authorized officer may grant permission to cut or destroy trees on NFS lands without advertisement when necessary for the occupancy of a ROW or other authorized use of NFS lands. Payment for timber of merchantable size and quality at its appraised value will be required, but at not less than applicable minimum prices established by Regional Foresters, and payment will be required for young growth timber below merchantable size at its damage appraisal value. Authorized removal must be consistent with applicable land management plans and environmental quality requirements and includes, as appropriate, requirements for:

• Fire protection and suppression.

• Protection of residual timber.

• Minimizing increases in soil erosion.

• Providing favorable conditions of water flow and quality.

• Minimizing adverse effects on or protecting and enhancing other NFS resources, uses, and improvements.

Using a method approved by the Agency, the utility must identify trees to be removed for safety reasons. The Agency will visit the area, mark and measure the trees (including stump marking), calculate volume, and prepare billing (if appropriate) for timber to be removed. If the utility is billed, payment must be received prior to cutting of trees. The utility must obtain written permission from the Forest Service prior to cutting. After review of operating areas, the authorized officer may place restrictions on timing of cutting and specify types of slash treatment required. B. Timber Valuation and Billing The authorized officer will determine whether to bill the utility for timber to be removed. In general, in operable areas, the Forest Service will charge for green merchantable timber proposed for cutting. The utility may also be billed for recent dead trees that are still merchantable. The Forest Service will consider the following when making this determination:


Appendix G – Page 1

1. Is there any market value? Are viable markets available in the vicinity? 2. Would removal be economical?

• Is there sufficient volume per acre?

• What is the size of trees to be removed (larger diameter = greater value)

3. Is the timber accessible? • If the timber is inaccessible, there is no charge.

While the Agency generally may not charge stumpage rates for commercial species of less than merchantable size, the authorized officer may assess other timber-related charges, including road maintenance deposits and damage rates, if such material will be removed. C. Timber Payment If an authorized officer has determined that billing for the timber is appropriate, payment rates for the timber must be determined. Options for determining timber payment rates, in order of priority, include:

1. Appraisal rates obtained through the transaction evidence appraisal program.

2. Comparison appraisal using appraisal rates from similar sales.

3. Standard rates from the applicable regional supplement to the Timber Appraisal Handbook, FSH 2409.22.

4. Minimum rates from the applicable regional supplement to FSH 2409.22.

Documents

FOREST SERVICE NATIONAL DESK GUIDE TO PREPARING VEGETATION MANAGEMENT PROCEDURES FOR ...a123.g.akamai.net/7/123/11558/abc123/forestservic... · 2014-07-16 · Guidance for Vegetation