PG&E Integrated Vegetation Management Program for Transmission Line Rightsof-Way and Access Roads (using herbicides and mastication), Eldorado National Forest PURPOSE AND NEED FOR ACTION Pacific Gas and Electric Company (PG&E) is required to manage vegetation that presents a risk to its electric transmission facilities. Various federal and state laws address this requirement, including Federal Energy Regulatory Commission (FERC) license articles, as well as FERC Safety Inspection (Chapter 5), and Public Resources Codes (PRC). Vegetation management is a critical component of ongoing operation and maintenance of PG&E transmission line facilities. The objective for PG&E's proposed use of mastication and herbicides as part of an Integrated Vegetation Management (IVM) program is to promote compatible vegetation (and eliminate incompatible vegetation) within the existing rights-of-way (ROWs) and along a 200 foot hazard tree zone (HTZ) established on each side of the ROW for the French Meadows - Middle Fork ROW (FERC No. 2479). Compatible vegetation is desirable or compatible with the intended use of the ROW. For example, plant species that would never grow sufficiently close to violate minimum clearances with electric conductors such as grasses, forb, and low growing shrubs. Compatible vegetation does not interfere with the safe and reliable transmission of electricity or the inspection and maintenance of facilities. Incompatible vegetation is undesirable or unsafe vegetation and may interfere with the intended use of the ROW now or at any time in the natural lifespan of the plant species. The existing vegetation management options in the ROWs do not include mastication or the use of herbicides and instead rely on manual labor such as pruning and removal of trees and brush species. This is inadequate to maintain control of brush and hardwood species that continuously re-sprout from the roots with increased stem density. The proposed IVM program including herbicide use with mastication in certain locations would promote and establish a more permanent change of vegetation structure within the ROW to maintain lowgrowing, native plant species that pose lower risk of conflicts with the transmission line. An economical and effective IVM program is needed to establish and maintain compatible/desirable plant communities within the transmission corridor and control incompatible species such as noxious or invasive weeds, those species with the potential to grow into and interfere with the conductors, and those brushy species that contribute to fuel loading. The transmission line ROWs and the HTZ along French Meadows-Middle Fork Transmission Line within the ENF require ongoing vegetation management and an integrated vegetation management program that includes the use of herbicides and mastication is intended to result in the most effective, long-term approach for facilities management. The proposed IVM program would improve public service, safety and reliability of the facilities, and reduce the risk of catastrophic wildfires. Herbicide Use and Mastication Vegetation Management Objectives: Improve efficacy of PG&E s vegetation management program and improve safety and reliability of electric transmission service. Prevent massive power outages, blackouts, and disruptions that can lead to injuries and possible fatalities. Comply with federal and state regulations for vegetation management in transmission line ROWs. Promote compatible vegetation within the transmission line corridors. Establish low growing native shrub-forbs-grass cover types in the wire zone and a taller shrub-forb-grass cover types in the border zones. Control incompatible vegetation within the ROW beneath the lines, poles and facilities out to the edge of the ROW.
Avoid the dense re-growth resulting from manual and mechanical-only tree and brush removal and subsequent re-sprouting of vegetation while minimizing the need for repeated removal methods. Access Road Management Goals Vegetation along access roads also needs to be maintained to improve site clearance, and site distance and to reduce fire risk from vehicles parked in the dry grass on the side of the road. Project Location The proposed work area footprint incorporates approximately 26 miles of electric transmission line corridor, and 591 ROW acres including an additional 200 foot HTZ along the French Meadows-Middle Fork ROW. The ROWs are variable in width ranging from 40 to 200 feet wide and the treatment area footprint identified in Table 1 below includes the maximum extent of the ROW or wire zone-border zone area. In addition, approximately 11.5 acres of transmission line access roads are proposed for herbicide treatment. These include project roads under Special Use Authorization and PG&E-maintained roads identified in the French Meadows Middle Fork Road Plan and Maintenance Agreement. Table 1 provides a summary of the locations where herbicides are proposed and the attached maps (Maps 1 through 3) display the locations of transmission line facilities and the HTZ. PROPOSED ACTION PG&E proposes the use of mastication and herbicides to maintain the required clearance from power lines (PRC 4293) and to clear (brush) vegetation from around the base of structures in accordance with California PRC 4292 and GO 95. Herbicide use is regulated by the U.S. Environmental Protection Agency (EPA), the California Environmental Protection Agency (CalEPA), Department of Pesticide Regulation (CDPR). Forest Service Handbook 2109.14 (USFS 1994a) guides pesticide-use on National Forest System lands and requires compliance with Forest Service standards and guidelines and other management direction. Herbicide Use Along Transmission Line ROWs: PG&E proposes the use of six herbicides within approximately 591 acres and in the project locations described above and in Table 1 below. Table 2 describes the proposed products and provides a brief description of why each herbicide is being proposed in this project including target species and timing considerations. This includes a broad and diverse group of herbicides with the intent of providing the flexibility and adaptability of vegetation management needs currently and those that may arise in the future. Having access to a wide range of active ingredients and modes of action would allow for the most appropriate herbicides to be prescribed for the control of target vegetation. The use of the most appropriate herbicides for species identified as incompatible within the ROWs, results in greater efficacy of treatments and the need for the least amount of herbicide necessary to achieve management goals. Herbicide prescriptions would assist with herbicide resistance management. All proposed herbicides have been approved by the US Environmental Protection Agency and the California Department of Pesticide Regulation. 2
Table 1. Summary of PG&E Proposed Herbicide Use within Transmission Line ROWs and Access Roads on the Eldorado National Forest TOTAL RANGER DISTRICT NAME GEORGETOWN RANGER DISTRICT FRENCH MEADOWS-MIDDLE FORK (FERC) Kilovolt s (kv) Special Use Authorization ID or FERC No. ROW Width (FEET) 60 FERC No. 2479 40 Attached Map Number USGS Quadrangle Map 1 USGS Quadrangle: Bunker Hill, Greek Store T-Line Miles ROW Acres Proposed Herbicide Use Work Area Acreage Proposed Herbicide Use Road Acres 12.48 446.51 438.80 6.12 6.40 31.55 31.55 FRENCH MEADOWS-MIDDLE FORK (FERC - HTZ) MIDDLE FORK #1 60 MIDDLE FORK-GOLD HILL 230 PLACERVILLE RANGER DISTRICT EL DORADO-MISSOURI FLAT #1+ & 2+ AMADOR RANGER DISTRICT NA FERC No. 2479 400 (440-40) kv 115 kv SALT SPRINGS-TIGER CREEK 115 GTN156 (Expires 2037) GTN156 (Expires 2037) Special Use Authorization ID or FERC No. PVL177 (Expires 2034) Special Use Authorization ID or FERC No. AMA208 (Expires 2034) 40 100 ROW Width (FEET) 200 ROW Width (FEET) 80 Map 1 USGS Quadrangle: Bunker Hill, Greek Store Map 1 USGS Quadrangle: Greek Store, Michigan Bluff, Tunnel Hill Map 1 USGS Quadrangle: Georgetown, Greek Store, Michigan Bluff, Tunnel Hill Attached Map Number USGS Quadrangle Map 2 USGS Quadrangle: Pollock Pines, Slate Mountain Attached Map Number USGS Quadrangle Map 3 USGS Quadrangle: Calaveras Dome, Devils Nose, Garnet Hill NA 326.90 326.90 3.48 16.90 13.18 6.75 81.99 67.18 3.12 76.06 60.84 2.08 3.12 76.06 60.84 9.90 95.97 91.14 3.27 9.90 95.97 91.14 Grand Totals (non-overlapping) 25.49 618.54 590.77 11.47 Notes on Methodology: Mileage is based on only the portions of Transmission lines within the specified project extents Overlapping Line ROW areas and miles are subtracted from Corridor ROW areas and miles, respectively 1 Areas excluded from proposed herbicide use include locations where there is 100 feet or more of clearance from ground to conductor height. In many cases, this excludes perennial streams in canyons. More detailed maps showing these exclusion areas are available upon request. 3
Table 2. Product, Target Species and Timing HERBICIDE (Trade Names 1 ) Aminopyralid (Milestone, Milestone VM or equivalent) Clopyralid (Transline or equivalent) Glyphosate (Accord, Rodeo or equivalent) Imazapyr (Chopper or equivalents) Triclopyr (Amine Formulation, Garlon 3A) Triclopyr (Ester Formulation, Garlon 4 Ultra or Forestry Garlon XRT) Adjuvant MSO Surfactant/Diluent (Hasten, Competitor (aquatic formulation) WHY NEEDED? TARGET SPECIES TIMING Effective as a selective pre- and post- emergent control of brush and broadleaf weeds. Selective post-emergent herbicide for control of specific broadleaf weeds. Very low use rate. Less potential for unintended impact compared to other herbicides. Ideal for native grass release. Key component of any IVM program that includes herbicides. Versatile, compatible, broad spectrum of use. Superior efficacy on brush and specific perennial grasses. Low use rates. Very specific application methods such as basal, frill and ultralow volume foliar. Selective control of brush and broadleaf species. Highly versatile. Broad spectrum and multiple application methods. Aquatic labeling. Selective control of brush and broadleaf species. Highly versatile. Effective for a number of species. Requires specific application methods including basal and dormant stem. Year-round application efficacy. Trade Names for Analyses Preferred surfactant and diluents. Necessary for all herbicide applications. Yellow starthistle, Rush skeletonweed, Italian thistle, Scotch Broom, & other resprouting species (pre-emergent to bolting for thistles & broadleaf forbs; summer to fall for brush TYPICAL APPLICATION TIME PERIOD Fall - Spring Yellow starthistle rosette to bolting Fall - Spring Scotch Broom, yellow starthistle, Oaks, Madrones, Manzanita, and other resprouting species Rush skeletonweed, yellow starthistle, scotch broom, Oaks, Madrones, Maples, Manzanita, and other resprouting species Scotch Broom, Oaks, Madrones, Maples, Manzanita, Blackberry, and other resprouting species Scotch Broom, Oaks, Madrones, Maples, Manzanita, Blackberry, and other resprouting species Spreader-Penetrator when target plants are actively growing when target plants are actively growing when target plants are actively growing when target plants are actively growing through the fall as plants begin to shut down Spring - Fall Year Round Spring Late Fall Spring Late Fall Year Round 1 Application rates not to exceed recommended label rate. 4
Table 2. Product, Target Species and Timing HERBICIDE (Trade Names 1 ) Marker Dye (Colorfast Purple) Non-ionic Surfactant (R-11) WHY NEEDED? TARGET SPECIES TIMING Necessary to identify precise applications of herbicide for public safety. Preferred surfactant for annual forbs and grasses. Marker Dye Spreader- Sticker TYPICAL APPLICATION TIME PERIOD Year Round Year Round The inclusion of herbicides to the IVM program would more effectively maintain a low growing grass, forbs, and shrub complex immediately under the conductors (wires) with a taller shrub complex adjacent to conductors and extending out to the edge of the ROW. In line with the American National Standard Institute s (ANSI) A300 Part 7 Standard Practices for IVM on Utility Rights-of-Way and the Utility Arborist Association s IVM Best Management Practices (BMPs). This management strategy is known as a wire zone-border zone vegetation management strategy as depicted below. The "wire zone" refers to the segment of the ROW directly beneath the transmission wires where the poles and facilities are located plus a minimum of 10 feet on both sides. The "border zone" encompasses the remainder of the ROW on both sides of the wire zone and extends from the wire zone to the edge of the ROW. The proposed vegetation management program is developed to manage for compatible species and herbicides would be used consistent with those management objectives. Typically this vegetation structure would take 5 to 7 years to establish with the use of herbicides. Herbicide Use Along Access Roads: Approximately 11.5 acres of transmission line access roads are proposed for herbicide treatment. These include project roads under Special Use Authorization and PG&E-maintained roads identified in the French Meadows Middle Fork Road Plan and Maintenance Agreement. The attached maps display the approximate locations of access roads proposed for treatment and Table 1 summarizes access road acres proposed for treatment, which are organized by Ranger District. PG&E proposes the use of herbicides to define and maintain clearance adjacent to the roadbeds of critical access roads and to designate pullouts along the roadways. The access roads are critical to PG&E for year-round maintenance of facilities. The types of herbicides, schedule and other conditions would be the same as those described above in Table 2 and under proposed treatment methods below for the transmission line ROWs. Mastication: PG&E proposes the use of mastication within approximately 161 acres inside the transmission line ROWs that are under Special Use Authorization (SUA). Mastication would be used on flatter slopes < 35%, which are accessible by road and where it is necessary to clear segments of ROW that are overgrown with larger and dense vegetation to re-establish or maintain corridors. PG&E is proposing the same mastication methods for the transmission lines under SUA as those already approved in the French Meadows Transmission Line (FMTL) corridor on the ENF. The acreage proposed for mastication by transmission line ROW is provided in Table 3 below. VEGETATION TREATMENT METHODS Proposed Equipment and Treatment Methods for the Application of Herbicides The California Department of Pesticide Regulation issues Agricultural Pest Control Adviser (PCA) Licenses which are required of any person who offers a recommendation on herbicide use, who holds himself/herself forth as an authority on agricultural use, or who solicits services or sales for agricultural use. For this proposed action, 5
Licensed Pest Control Advisors would manage and prepare all recommendations for the use of herbicides. All herbicides proposed for use have been approved by the Environmental Protection Agency (EPA) and California Department of Pesticide Regulation (CDPR) and they are recommended by CDPR. The PCA recommendations would be established annually based on vegetation management needs and as part of obtaining annual Eldorado National Forest Pesticide Use Permits. The PCA recommendations would be strictly adhered to at all times. PG&E would also coordinate as needed with the appropriate County Agricultural Commissioners and all PCAs would be registered within El Dorado, Placer and Amador Counties. The majority of applications (approximately 95%) would be manual, made with backpack application equipment. Crew sizes can range from 4 to 12 depending on ROW width and prescribed application methods. Work crews would consist of a foreman who is a qualified licensed applicator (QAL). Additionally, an independent Pest Control Advisor (PCA) would be on site to oversee the application for the duration of the project. Herbicide mixing would be limited to areas inside the ROW, and completed in accordance with stream buffer widths to be defined in the Design Criteria and in accordance with the manufacturer s labels. A licensed PCA prepares in advance a site specific prescription for the use of herbicides for every project. Prescription of a herbicide would result from pre-application site visits to assess conditions and determine the best method of vegetation control. Site assessments include several environmental and biological factors. These factors include but are not limited to the following: existing vegetation composition, topography, soil type, hydrologic features, surrounding wildlife, including Threatened and Endangered species, domestic animals, livestock, resident adjacency, apiaries, and proximity to and volume of recreational use. Based on the site assessment, the PCA would prescribe the appropriate method of control including herbicide. Specific to the herbicide prescription, the advisor describes the appropriate active ingredient and formulation, application rate, timing and application method for each location. The annual Pesticide Use Permits submitted to the ENF for approval would identify specific active ingredients, target species, and locations to be applied. Four-wheel-drive pickup trucks and specially fitted service trucks are proposed to carry herbicides, water, crew and other equipment necessary for applications. All-terrain vehicles (ATVs) would be used to a limited extent for transporting crews to remote worksites, serving as a smaller satellite batch tank, and in some instances for application using a hand wand or quad mounted low boom for applications to roads or other areas appropriate for use of mechanized application equipment. Proposed application methods include foliar, basal, cut stump, frill, or hack and squirt, and soil applied preemergent; both selective and non-selective. These application methods are described below. Foliar Backpack Application: Involves spraying an herbicide from a backpack sprayer, where the herbicide application is directed towards target vegetation or areas of infestation. Spray nozzle is no more than 24 inches above target vegetation. This method can be selective or non-selective, depending on the type of herbicide used and specific type of application. For example, the broadleaf selective herbicide triclopyr is most effective when applied to target vegetation (e.g., broadleaf weedy species) in active growth. The mode of action is such that broadleaf species are controlled without affecting desirable grass species. A non-selective herbicide such as glyphosate can provide selective control through the use of low-volume, directed backpack applications directly to target species, or by timing the application at undesirable vegetation after non target plant species have gone to seed. Basal Stem Application: Selective systemic application method using backpack sprayers. An herbicide would be diluted in an oil carrier (e.g., Imazapyr (bi-phasal) or Triclopyr ester with modified seed oil [MSO] as a diluent) and applied to the lower 12 to 18 inches of the target woody plant. The combination of herbicide and oil penetrates the bark providing the desired control. Basal stem applications are most effective between the months of June and November, but may applied year-round specifically during the plant dormancy period when woody stems are void of leaves and more accessible. 6
Cut-Stump Application: Used to prevent woody species from re-sprouting. After trees and brush are manually/mechanically cut with a chainsaw or loppers, the stumps are treated with herbicide. Cut-stump treatments can be made year-round. This type of application is target specific with a low risk of run-off or drift. Applications are made using a back pack, hand can or hand held wick device. Frill, or Hack and Squirt Application: A selective control method used for woody plant species. In this application method, a frill or hack is made with a hatchet into the woody cambium and a small amount of undiluted herbicide is injected into the frill using a 1-quart handheld spray bottle. The herbicide gradually translocates to the roots and stems. Proposed Equipment and Treatment Methods for Mastication The equipment to be used for mastication includes large, steel tracked boom-type machines or small, frontmounted tracked or rubber-tired mastication equipment.tracked boom-type machines are highly maneuverable, and rotating booms cover a wide swath, reducing the number of passes required by the machine, thereby reducing ground impacts. Treating material can occur in a single action or it can take two to three passes with the head over the small trees or brush. Chips are left on the ground creating a mat of residue material for the machine to travel across. Small, front-mounted tracked or rubber-tired mastication machines are ideal for covering large areas of flatter slopes with smaller diameter woody debris and vegetation. This type of masticator/shredder is ideal for low impact operations in the Project area. Smaller, tracked equipment generally exerts very low ground pressure, often less than a human footprint. Table 3 provides a summary of the PG&E proposed mastication acres. Table 3. Summary of PG&E Proposed Mastication Use within Transmission Line ROWs on the Eldorado National Forest APPROXIMATE ACRES PROPOSED NAME OF TRANSMISSION LINE FOR MASTICATION Salt Springs-Tiger Creek 76 Middle Fork #1 10 Middle Fork-Gold Hill 45 El Dorado-Missouri Flat #1+ & 2+ 30 PREVIOUSLY APPROVED ACRES NAME OF TRANSMISSION LINE PROPOSED FOR MASTICATION French Meadows Where feasible. No acreage limit identified. VEGETATION MANAGEMENT SCHEDULE AND MAINTENANCE GUIDELINES This vegetation management program proposes the use of mastication and herbicides annually to control vegetation within PG&E Transmission Line ROWs and along access roads. Once approved, the program would remain in effect for 10 years with applications for Pesticide Use Permits submitted annually as per by the Special Use Easements. The annual submittals would include a list of facilities and proposed herbicide treatments to be used that year and the timing of treatments. This program would be updated as necessary to meet regulatory requirements and to incorporate additional analysis, if warranted. At a minimum, after 10 years of program implementation a review would be conducted to determine whether further analysis is recommended. Depending 7
on the results of this 10 year review, a letter to the file would be made part of the NEPA Project Record stating any changes to the recommendations for future use of herbicides. It is anticipated that treatment activities would be most intense the first two years of implementation to achieve control of overgrown vegetation. After the first two years and once unwanted vegetation is under control, it is anticipated the level of treatment activities to maintain control would decrease. Maintenance would occur every one to seven years depending on field conditions. PG&E would continue to perform annual routine line clearance patrols to identify vegetation that is or would be a compliance issue within 12 18 months (see PRC 4292, 4293, CPUC GO 95, and/or ISO Guidelines). Herbicides would be used as needed to maintain the ROWs in the desired condition to the standards defined as wire zone/border zone method, see above. Rights-of-Way The Forest Service approval for vegetation clearing is conducted as part of the annual operating plans for the ROWs and in accordance with the Special Use Easements. In cleared areas, the first selective backpack foliar herbicide application would occur when the vegetation reaches appropriate size, typically one growing season following clearing. In areas that are manually cleared with a cut stump herbicide application at the time of clearing, the first selective backpack foliar herbicide application typically occurs one to four years after the initial clearing when the vegetation reaches appropriate size. For both backpack foliar and cut stump herbicide applications, the next application typically occurs three to five years later, with the ultimate goal being between five and seven years. Access Roads The Forest Service approval for clearing access roads is conducted as part of the Road Use Agreement. As described above for the ROWS, in cleared areas the first selective backpack foliar herbicide application would occur when the vegetation reaches appropriate size, typically one growing season following clearing. In areas that are manually cleared with a cut stump herbicide application at the time of clearing, the first selective backpack foliar herbicide application typically occurs one to four years after the initial clearing when the vegetation reaches appropriate size. For both backpack foliar and cut stump herbicide applications, the next application typically occurs three to five years later, with the ultimate goal being between five and seven years. 8