HomeMy Public PortalAboutBOH 7.19.23 packet
EVERSOURCE ENERGY, EASTERN MA
FIVE YEAR VEGETATION MANAGEMENT PLAN FOR
CAPE COD AND MARTHA’S VINEYARD
(BARNSTABLE AND DUKES COUNTIES)
2023-2027
Submitted by:
Eversource Energy, Eastern MA
. August 31, 2022.
Revised/resubmitted date:
April 27, 2023.
Revised/resubmitted date:
May 23, 2023.
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TABLE OF CONTENTS
1. Introduction……………………………………………………………….... 1
2. Goals and Objectives………………………………………………………. 2
3. Identification of Incompatible Vegetation…………………………………. 3
4. Integrated Vegetation Management……………………………………....... 6
5. Mechanical Controls……………………………………………………….. 9
6. Chemical Controls…………………………………………………………. 13
7. Definition, Identification and Treatment of Sensitive Areas………………. 20
8. Operational Guidelines for Applicators relative to Herbicide Use……….... 27
9. Alternative Land Uses…………………………………………………….... 30
10. Remedial Spill and Emergency Plan……………………………………….. 31
11. Identification and Qualification of Individual Developing and
Submitting the Plan………………………………………………………… 35
ILLUSTRATIONS
1. Wire Zone-Border Zone Approach……………............................................. 4
TABLES
1. Herbicide Manufacturers…………………………………………………… 31
2. State Agencies………………………………………………………………. 31
3. Emergency Services………………………………………………………… 32
4. Local Emergency Numbers Table Format………………….......................... 32
5. Herbicide Spill Check List………………………………….......................... 33
APPENDICES
1. Electric System Maps
2. List of Municipalities
3. 333 CMR 11.00
4. Chapter 132B
5. Sensitive Area Table
6. Preface to 310 CMR 10.00
7. Wetlands Study
8. Chapter 85, Section 10
9. References
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1. INTRODUCTION
Eversource Energy, Eastern MA (Eversource) hereby submits this Vegetation
Management Plan (VMP) in compliance with 333 CMR 11.00, Rights of Way
Management regulations (Appendix 3).1
Eversource Energy, Eastern MA delivers electricity to approximately 1.1 million
electric customers in 81 municipalities and has the responsibility to manage vegetation
on company electric rights-of-way (ROW) and to ensure the safe and reliable delivery of
electric power to its customers. Electricity is transmitted over 89 miles of electric
transmission ROW, voltages 115kV, 230kV & 345kV and 55 miles of electric
distribution ROW, voltages 4kV to 25kV throughout communities within Cape Cod and
Martha’s Vineyard, Massachusetts (Appendices 1 & 2).
Eversource is responsible for maintaining its ROW free from hazards and
encroachments. Vegetation can interfere with electric service causing interruptions
by growing into the area around the conductors, falling into the conductors or
blowing together. Vegetation can inhibit access for maintenance and inspection.
Vegetation that comes in contact with conductors can ignite wildfires. Downed
wires can be a safety risk to workers attempting to clear vegetation or others that
come upon an incident and are close enough to come in contact with electricity. The
Eversource vegetation management program provides for the necessary safety,
system reliability, access to facilities, regulatory compliance, and security following
utility vegetation management industry best management practices (bmp).2
1A partial list of the regulations that Eversource must comply with that relate to the activities in this
document also include: Chapter 132 B, Pesticide Control Act (Appendix 4); all pertinent clauses in
Chapter 85 of the Acts of 2000 (Appendix 8); MESA; MGL c.131, Massachusetts Endangered Species Act
and its regulations, 321 CMR 10.00, Massachusetts Endangered Species Regulations; 310 CMR 10.00,
Wetlands Protection Regulations; 310 CMR 22.00, Drinking Water regulations; Chapter 216, An Act
Relative to the Emergency Service Response of Public Utility Companies; NERC Standard FAC-003-1,
Commissioner Order 69, and all applicable Federal Occupational Safety and Health Act, Department of
Transportation and Department of Environmental Protection regulations.
2 Miller, R.H. 2012. Best Management Practices: Integrated Vegetation Management.
Society of Arboriculture, Champaign, IL. Galen Guerrero-Murphy, Tim Follensbee II, and Jeff Disorda
2015. Best Management Practices (BMPs) for Protection of Threatened and Endangered Species during
Integrated Vegetation Management and Operations and Maintenance of Electric Transmission Lines in
Vermont. Environmental Concerns in Rights-of-Way Management, 11th International Symposium, Halifax,
Novia Scotia.
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Eversource’s program applies an Integrated Vegetation Management (IVM)
approach to controlling vegetation on its rights-of-way. IVM uses a combination of
maintenance techniques that include mechanical, herbicide and cultural control.
Herbicide maintenance application techniques are at the lowest effective labeled rate and
are timed for maximum effect. The IVM based program encourages low growing plant
communities that allows for the safe delivery of reliable electric service while minimizing
the impact on property owners and supports a more diverse habitat for wildlife that
depends upon early successional landscapes.
2. GOALS AND OBJECTIVES
Eversource is responsible to manage the property under its electric powerlines to
ensure the safe and reliable delivery of electric power to its customers. To achieve this
goal, Eversource has prepared this VMP to describe its practices and procedures for
managing vegetation that is undesirable, presents a safety hazard, or is otherwise
unsuitable to the intended use of the ROW.
This section serves to communicate objectives that will be accomplished
through the VMP, Yearly Operational Plans (YOPs) and notification processes required
by 333 CMR 11.00.
The following are objectives of Eversource’s vegetation management program:
• To maintain ROW that ensures the safe and dependable delivery of electricity.
• To manage vegetation that impedes ground and aerial inspections or
interferes with the ability to access the ROW and structures for maintenance
or emergencies.
• To encourage stable early successional ecological communities of primarily low
growing plant communities to allow access for maintenance and inspections
and ultimately reduce the amount of herbicide over time.
• To remove or manage incompatible vegetation on the ROW, along access
roads, around structures, gates, and the perimeter of electric substations.
• To control invasive and poisonous plant species.
• To ensure that all vegetation management operations are conducted in a safe,
effective manner and in conformity with all federal and state laws, regulations,
and permit conditions.
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3. IDENTIFICATION OF INCOMPATIBLE VEGETATION
The intent set forth in Eversource’s VMP is all vegetation that obscure the ROW
corridors and grow tall enough to interfere with the safe, efficient, and legal operation of
an electrical power line is considered “incompatible” with the intended use of the ROW
and therefore will be removed.
Eversource Arborists will determine the type of maintenance methods. The
management of vegetation within the established cleared limits of the ROW may be
performed in one of two ways, a two-zone management approach or a one-zone
approach. The method designated is based on the transmission facilities, number of
facilities (lines) within ROW, width of maintained cleared limit or easement,
topography, and plant community. Each ROW is designated as one or two-zone
maintenance by the Eversource Arborist.
1. Two-Zone Maintenance. Management of vegetation within ROW clearing
limits shall be performed in accordance with the two-zone maintenance
concept for designated transmission ROWs. A wire and a border zone shall
be developed and maintained in accordance with these specifications
(Illustration 1, Diagram 1).
Wire Zone: The wire zone shall include the area directly beneath the overhead
conductors extending outward a distance from the outermost conductor(s) based
on voltage:
Voltage Class Wire Zone
<230kV 25 feet
>=230kV 35 feet
Border Zone: The border zones shall include all areas from the Wire Zone limit
to the edge of the maintained width of the ROW. Border zone widths are variable
depending on ROW and extend to the edge of clearing.
2. One-Zone Maintenance Management of vegetation within ROW boundaries shall
be performed for ROWs designated by Eversource as one-zone. The entire
maintained width of the ROW is managed as a wire zone (Illustration 1, Diagram 2).
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Illustration 1: One-Zone or Two-Zone Maintenance, and Wire Zone-Border Zone Approach.
Diagram 1
Diagram 2
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Examples of incompatible tree species include, but are not limited to:
alder cherry pine
aspen hemlock maple
beech hickory oak
birch locust sassafras
Compatible plant species are generally encouraged on the ROW. Most
herbaceous growth is acceptable and encouraged. Small trees and shrubs that mature
less than 25 feet in height (Border Zone) are not usually incompatible unless due to
their location or attributes they interfere with the function of the ROW.
Some lower growing vegetation may be deemed incompatible because of their
location and/or their nature. Dense woody vegetation, shrubs and vines are incompatible
where they are capable of interfering with the inspection and maintenance of the poles,
wires, access roads, paths, and gates, all of which need to be kept clear, especially for
emergencies.
INVASIVE, POISONOUS PLANTS AND NUISANCE PLANT SPECIES
Eversource intends to selectively manage invasive, poisonous and nuisance plant
species with herbicide spot treatment and mechanical methods within the ROW. These
categories of plants are as defined below.
Nuisance Vegetation
Nuisance vegetation is plant species that pose a risk to the safety and health of
individuals working on or traversing a ROW and it can impede a rapid response in an
emergency. Example of nuisance vegetation include blackberry, raspberry, wild
grapevine, greenbrier, and many invasive plant species which have heavy thorns, dense
foliage and/or impenetrable stems.
Poisonous Plants
Examples of poisonous plants are poison ivy and poison oak. These pose a
health hazard to Eversource personnel, contractors and the public-at-large; therefore, the
company plans to use herbicides to spot treat poisonous plants at sites identified as
having a risk of posing a health hazard.
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Invasive Plant Species
Invasive plant species are a significant concern throughout Massachusetts in areas
that include ROW corridors where they can spread rapidly. Many of these non-native
plant species were planted for their showy flowers, vigorous growth, erosion control and
abundant fruits that attract wildlife. According to the Massachusetts Invasive Plant
Advisory Group, "invasive plants" are non-native species that have spread into native or
minimally managed plant systems in Massachusetts.
https://www.mass.gov/service-details/invasive-plants
These plants cause economic or environmental harm by developing self-
sustaining populations and becoming dominant and/or disruptive to those systems.
Eversource's program considers the management of invasive plants in specific
locations.
To ensure the accurate identification of vegetation, all vegetation management
contractors are required to supply personnel trained to recognize plant species typically
found growing on utility sites and to recognize the difference between compatible and
incompatible vegetation. The identification or early successional communities that are
preferred on an electric ROW will be included in this training.
4. INTEGRATED VEGETATION MANAGEMENT
333 CMR 11.01(1) requires that all rights-of-way managers “Ensure that an
Integrated Pest Management (IPM) approach to vegetation management is utilized on all
rights-of-way covered by 333 CMR 11.00.” The purpose of this VMP is to advance the
consistent and safe operation of Eversource’s ROW using the appropriate industry
standard IVM program. Eversource’s IVM program will use mechanical, chemical, and
cultural control methods. Mechanical and chemical control methods are used to facilitate
development of a low-growing plant community. These methods of converting to and
sustaining a low growing plant community are referred to herein as “cultural control.”
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Eversource’s IVM program takes into consideration all factors involved in the
maintenance and operation of electric ROW that includes:
• Conditions existing on its ROW such as topography and hydrology.
• The most current treatment methods.
• The intent to prevent unreasonable adverse effects to the environment and the
safety and health of non-target organisms including humans.
• Cost-effectiveness of the treatment both for Eversource and their customers,
including the need to deliver energy products safely and economically.
• Monitor the result of treatments to compare actual conditions to desired
future conditions to improve the program.3
There is no single definition of IVM that suits every situation and every entity.
According to the United State Environmental Protection Agency, Office of Pesticide
Programs:
“Integrated Vegetation Management (IVM) is generally defined as the
practice of promoting desirable, stable, low-growing plant communities -
that will resist invasion by tall growing tree species-through the use of
appropriate, environmentally sound, and cost-effective control methods.
These methods can include a combination of chemical, biological,
cultural, mechanical, and/or manual treatments. The IVM approach
strives to manage vegetation and the environment by balancing the
benefits of: Cost, Control, Environmental quality, Public health, and
Regulatory compliance.”
Integrated Vegetation Management Fact Sheet (October, 2008) (epa.gov)
Eversource’s IVM program follows a combination of mechanical (mechanical—
handheld and large equipment—methods) treatment typically every four years and
herbicide (chemical methods) applications the year thereafter that support the ability to
convert to a low growing plant community (cultural method).
Plant life is governed by the relatively predictable process of change in
composition or structure of ecological succession. Succession strives towards the mature
(climax) forest but may be interrupted by natural or human disturbances both
intentionally and accidentally. IVM programs are an intentional human disturbance
that encourage early successional communities. This is achieved by discouraging the
3Christopher A. Nowak & Benjamin D Ballard. “A Framework for Applying Integrated Vegetation
Management on Rights-of-Way.” Journal of Arboriculture 31(1) (January 2005): 28-37.
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establishment of, and when necessary, removing certain types of vegetation.
Eversource’s approach reduces the amount of herbicide used by using selective
herbicides/application techniques at the lowest effective label rate, timing
applications for maximum effect, avoiding fixed application schedules, using
mechanical control techniques where appropriate, and encouraging low growing
plant communities.
Mechanical and chemical controls are the direct techniques used to target
incompatible vegetation and include mowing, hand-cutting, side pruning, tree removals
and herbicide applications. Utilizing these techniques allows lower growing plants the
opportunity to form sustainable ecological communities. Regeneration of low growing
native plants is an important part to our utility IVM program as it helps to stabilize the
floor of the ROW with plants that are compatible with electrical conductors and allows
access. Once achieved, early succession plant communities require less management
thereby reducing future chemical use and disturbance caused by mechanical methods.
There is over seventy years worth of evidence in New England showing that this
approach has, over time, significantly reduced the per- acre application rate of herbicides
on utility ROW and reduced the need for intensive mechanical controls. 5 Following this
approach the company has over time, reduced the amount of herbicide used per acre.
Under a mechanical only program our rights-of-way were once dominated by high stem
densities of incompatible tree species.
__________________________
5Environmental Consultants, Inc. “Study of the Impact of Vegetation Management Techniques on
Wetlands for Utility Rights of Way in the Commonwealth of Massachusetts.” Prepared for New England
Electric et.al, 1989; Environmental Consultants, Inc. “Determination of the Effectiveness of Herbicide
Buffer Zones in Protecting Water Quality on New York State Powerline Rights-of-Way.” Final report for
the Empire State Electric Energy Research Corporation, 1991; K.H. Deubert. “Studies on the Fate of
Garlon 3A and Tordon 101 Used in Selective Foliar Application in the Maintenance of Utility
Rights of Way in Eastern Massachusetts.” Final Report prepared for New England Electric et.al., 1985.
N.H. Nickerson, G.E. Moore, and A.D. Cutter. “Study of the Environmental Fates of Herbicides in Wetland
Soils on Electric Utility Rights-of-Way in Massachusetts over the Short Term.” Final Report prepared for
New England Electric et.al, December 1994; Matt Hickler, NHESP approved Review Biologist, Reports for
TransCanada, National Grid, NSTAR Electric, and Northeast Utilities under 321 CMR 10.00
Massachusetts Endangered Species Act Regulations, 2006-2010; “Utility Transmission Forestry Herbicide
Use Summary Records” for NSTAR Electric, Vermont Electric Power Company, TransCanada Hydro
Northeast, Inc and National Grid USA Electric Companies (see National Grid 5 year VMP 2009-2013, p.
9); C.A. Nowak and L.P. Abrahamson, “Vegetation Management on Electric Transmission Line Rights-of-
Way in New York State: The Stability Approach to Reducing Herbicide Use.” Proceedings of the
International Conference on Forest Vegetation Management, Auburn University, April 1993.
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5. MECHANICAL CONTROLS
Mechanical controls include hand cutting, mowing of trees and incompatible
brush, side pruning and removal of mature trees. Eversource vendors comply with the
ANSI A300 (part1) for Tree Care Operations - Tree, Shrub, and other Woody Plant
Management - Standards Practices (Pruning). The following section lists their uses and
sets some basic guidelines.
HAND CUTTING
Definition:
The use of chainsaws and brush saws to remove the stem of woody vegetation
at ground level leaving the plant’s root system intact.
Uses:
• To remove incompatible vegetation on the floor (Illustration 1) of the ROW.
• In chemical restricted sensitive areas where herbicides are prohibited.
• Allows for selectivity in targeting incompatible vegetation.
Operational Practices:
• Trees are cut as close to the ground as possible so that stump height is
close to the root flare.
• Cut stems are windrowed or chipped.
• Depending on the situation windrow are positioned parallel along the edge
of the ROW corridor and should not exceed 2ft. in height.
• Cut woody vegetation in yards or recreational sites will be chipped and
disposed of or removed to adjacent areas.
• Cut woody vegetation is not left on or across paths, roads, fence lines, stone
walls or in waterways or in such a manner that would permit it to wash into
these areas.
• The placement of cut woody vegetation must comply with applicable State
Fire Marshall’s regulations.
• Chipping is used on sites designated by Eversource when leaving brush
piles is prohibited or impractical.
• No chips shall be left in wetlands.
• All cut cherry and red maple is removed from private property active
pastures as it is a hazard to grazing animals.
MOWING
Definition:
The cutting, severing, of vegetation by rotary or flail mowers. These mowers,
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usually ranging from 3-8 feet wide, are typically mounted on a four-wheel drive
rubber-tired tractors or tracked vehicles.
Uses:
• Can be the preferred mechanical technique, especially on sites where
extremely tall and dense incompatible vegetation makes hand cutting
inefficient and expensive.
• Where herbicides are prohibited.
• To allow access for inspections of vegetation conditions during ROW patrols.
Operational Practices:
• Mowing may be restricted by terrain conditions such as steep, rocky sites
or wet soils.
• It requires the use of hand cutting methods next to obstructions such as
stone walls and fence lines.
• Mowing brush can throw large chips and debris great distances from the
cutting equipment and requires employing someone to prevent people and
animals from coming too close to the work site.
• Measures may include matting of wetland areas, installation of silt fences
and chipping and removal of all debris.
• The bounds will be accurately located, to minimize erosion and potential
damage due to ruts, and to minimize impact to the environment.
SIDE PRUNING
Definition:
Side pruning of tree branches growing on or near a ROW. This management
technique is usually accomplished using an aerial lift mounted on an off-road
vehicle or mechanical side trimmer. Tree climbing is sometimes employed in
situations where terrain prevents the passage of equipment.
Uses:
• Remove incompatible vegetation from growing into the conductors from the side.
• Maintaining the edge definition of the ROW corridor.
• To facilitate, expedite, and increases efficiency of the inspections
of vegetation conditions during ROW patrols.
Operational Practices:
• All pruning activities are performed in accordance with proper
arboriculture practices to insure the health and aesthetic value of the trees
as well as all applicable regulations.
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REMOVALS
Definition:
Removal of trees that have become a hazard to the ROW or that may have been
overlooked in previous treatment cycles and allowed to encroach the ROW and
the lines and conductors. In these cases, trees will be removed in such a way that
they cannot strike wires, guy wires, structures, appurtenances, and adjacent
properties. In most cases, these trees will be addressed using aerial lift equipment,
but may require climbing where terrain dictates. Larger overhanging limbs may
require rigging to safely control the fall of cut material. Trees that do not
overhang or directly threaten the line may be “pieced down” by removing
material from the top down in small sections that cannot strike the line or cause
damage. In cases of severe encroachment on a larger scale, qualified and
appropriate timber harvesting equipment and contractors may be employed to
clear the ROW up to the edge of easement.
Uses:
• To keep trees from striking electric conductors, guy wires and structures.
• Maintaining the edge definition of the ROW corridor.
• To facilitate, expedite, and increases efficiency of the inspections
of vegetation conditions during ROW patrols.
Operational Practices:
• All removal activities will be performed by qualified line clearance
arborists.
• Measures may include matting of wetland area, installation of silt fences
and chipping and removal of all debris.
• Care will be taken to accurately locate the bounds of activity, to minimize
erosion and potential damage due to ruts, and to minimize impact to the
environment.
BENEFITS AND LIMITATIONS
Eversource’s mechanical controls are the method of management where the use
of herbicides may be prohibited or restricted in various sensitive areas. Sensitive areas
include defined distances per regulation near drinking water supplies (both private and
public), wetlands or water over wetlands, rivers, certified/potential vernal pools, and
agricultural or inhabited areas (see Section nine). Certain Priority Habitats defined by
Massachusetts Division of Fisheries and Wildlife, Natural Heritage Endangered Species
Program (NHESP) call for the use of mowing instead of, or in conjunction with,
herbicide applications to encourage or restrict the height of various host plants.
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Mechanical treatment methods are also used in the following situations: on
vegetation over 15 feet in mature height; in preparation for some herbicide treatments; in
individual areas deemed as sensitive; around structures; on access roads; to clear
easements; and in areas of thick impenetrable vegetation. In large areas of high-density
stems where incompatible species have exceeded maximum herbicide treatment heights,
a mechanical treatment may be more practical, followed in one or two growing seasons
by an herbicide application to obtain effective control. This includes along the easement
edges where trees are cleared or pruned to maintain the width of the ROW. Upon
establishing the easement edge, the cleared area of the ROW is managed by the Wire
Zone-Border Zone approach using the appropriate treatment methods. The electric utility
easements are areas of a property that were defined for use by utility companies when the
property was first put on a property map.
Mechanical controls on their own are only a short-term solution to controlling
vegetation on a ROW system. Mechanically cut vegetation often re-sprouts with
multiples of stems from dormant buds on the root collar resulting in a stem density that is
significantly greater than the original vegetation cut. An annual program that uses only
mechanical treatment cycles increases dense areas of woody vegetation. This vegetation
competes with and dominates the low growing vegetation Eversource wishes to
encourage.
When relying on mechanical control methods alone, dense areas of incompatible
vegetation can become costly and dangerous to hand-cut with power saws and are best
controlled by mowing. Large mowing equipment, although an excellent IVM tool, can
have a negative impact on compatible plant communities whose establishment is crucial
to developing successful cultural controls. Mowing can also create a potential seedbed
for fast growing, pioneering incompatible species such as poplars, cherries, birches, and
various invasive species. This can increase the frequency of the maintenance cycle and
destroy the dominance of stable, diverse early successional plant communities. Similarly,
sensitive areas, such as wetlands and residential areas can be adversely impacted when
crossed by mechanical maintenance equipment.
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6. CHEMICAL CONTROLS
Chemical controls are herbicide applications which include foliar, basal, and cut
stump surface treatments (CST), and plant growth regulator (PGR) applications. They
are a vital year-round component of an IVM program geared to establishing and
stabilizing early successional plant communities and promoting the development of
cultural controls to maintain this goal. The following sections describes guideline and
application methods.
GENERAL GUIDELINES
• Eversource requires an advance person or “prep-cutting” crew to patrol the ROW
before the herbicide application operation.
• Sensitive areas will be identified and appropriately measured and flagged, then
verified and recorded when appropriate in cooperation with local water suppliers
and conservation commissions.
• Herbicides will NOT be applied during the following adverse weather conditions:
When the wind velocity is such that there is a high propensity to drift off
target and/or during measurable precipitation, and no person shall apply
herbicides in such a manner that results in drift into any No-spray Area.
During periods of heavy rainfall.
Foliar applications of volatile herbicides when temperatures exceed 89
degrees Fahrenheit and low humidity.
CST or Basal application when deep snow (i.e., 6” plus or ice frozen
on stem or stump) prevents adequate coverage of incompatible species
to facilitate acceptable control.
Basal applications when the stems are excessively wet from moisture.
• Herbicides are not applied:
To vegetation standing in surface water.
Within no spray areas per 333 CMR 11.00.
FOLIAGE APPLICATIONS
Definitions:
The application of herbicides to fully developed leaves, stems, needles, or blades
of a plant.
Low Volume Foliar:
Hand-operated pumps or motorized, backpack sprayers with herbicide
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concentrations per the manufacturers’ label(s). The motorized backpack
sprayer produces an air current that delivers the herbicide mixture from the
portable spray tank to the targeted vegetation. The hand sprayer uses a
column of water. In both cases, the amount of herbicide solution applied only
dampens or lightly wets the targeted vegetation, instead of being applied to
the point of run-off. This minimizes the amount of excess herbicide drip from
incompatible species onto desirable ground cover. Low volume applications
also eliminate the need to bring heavy equipment on the ROW for the
transportation of significant quantities of herbicide solution.
Modified Low Volume Foliar:
Uniform, penetrating herbicide mixtures delivered to dense incompatible
vegetation. This technique usually involves 200-to-500-gallon hydraulic
sprayers mounted on a truck or tractor equipped with several hundred feet of
hose and hand-held spray guns. The herbicide mixture can be directed to
specific plants for spot treatments or broadcast for uniform coverage in dense
thickets of nuisance plants such as poisonous or invasive plant species.
Uses:
• An effective control method in light and medium brush densities to kill target plant root
systems.
• Effective control of some invasive, nuisance and poisonous vegetation.
• Allows for selectivity in targeting vegetation.
General Guidelines:
• Herbicides are mixed and applied per label instructions.
• Low pressure foliar application equipment will be adjusted to apply a
spray pattern that achieves effective control at the lowest application rate.
• Application period usually extends from early June through the beginning
of leaf drop in early fall.
• Anti-drift agents are added to the mix or solution in all foliage
applications to reduce the potential of herbicide drift beyond targeted
vegetation—drift control agents reduce the break-up of sprays into fine
droplets and offer increased selectivity, leaf tissue penetration, and
herbicide deposition on targeted vegetation.
• Foliar applications can be made, and are effective, in light mist conditions.
• When foliar applications are stopped by rainfall, treatment will not resume
until the rain ends and water no longer creates a shield to accept herbicide
application.
• No herbicide shall be applied when the wind velocity is such that there is
a high propensity to drift off target and/or during measurable
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precipitation, and no person shall apply herbicides in such a manner that
results in drift into any No-spray Area.
LOW-VOLUME STEM BASAL
Definition:
• The selective application of herbicides in an oil solution to the lower 12-
15 inches of the stem using a solid cone or flat fan nozzle.
Uses:
• Year-round application technique, except during deep snow conditions
that cover the target area.
• Typically employed during the non-foliage season when targeted stems
are easier to identify without the interference of lush, tall grasses or ferns.
Guidelines:
• Utilizes hand-operated backpack sprayers.
• Use a basal oil made for herbicide application to penetrate the bark.
• Not an appropriate method to control high stem densities due to high
herbicide rates per acre.
• Extending the herbicide treatment period beyond the foliage
season.
• May be the appropriate choice for visually sensitive areas.
CUT STUMP SURFACE TREATMENT (CST)
Definition:
The application of an herbicide mixture to the cut surface of a stump immediately
following or during a cutting operation using an herbicide concentration, diluted
in water or a non-freezing solution.
Uses:
• Year-round applications except during deep snow conditions that prevent
cutting the stumps low enough.
• Offers the opportunity to chemically treat incompatible vegetation where
other methods are not possible.
• Commonly used to prevent re-sprouts when hand cutting vegetation.
Guidelines:
• Application equipment includes low-volume, backpack, hand-pump
sprayers; hand-held squirt bottles; paintbrushes, or sponge applicators.
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• Only necessary to treat the outer edge of the cut surface (phloem and
cambium tissue), regardless of the stump diameter.
• Treatment made to cut stumps per label instructions.
• Best to avoid using it during the season of bud swell to full leaf expansion.
• Not practical in moderate to heavy stem densities.
TREE GROWTH REGULATORS (TGR)
Definition:
Tree Growth Regulators (TGRs) are plant growth regulator chemicals that
manage or reduce the potential growth rate of trees.
Uses:
• Useful especially along street distribution lines where repetitive trimming
is necessary to maintain adequate tree-electric conductor clearances.
• Can lengthen the time frame between trimming cycles and improve the
aesthetics of street and yard trees that may otherwise require removal or
severe pruning.
Guidelines:
• Applied as basal drench around the base of the tree.
• Applied as a soil injection next to the buttress root zone.
JUSTIFICATION AND RATIONALE FOR USE OF HERBICIDE
Eversource is responsible to deliver energy products to its customers in a safe and
efficient manner and to control vegetation on its ROW. To meet these obligations in an
ecologically sound manner, as discussed above is best accomplished by stabilizing early
successional ecological communities on ROW.6 Eversource needs to use all treatment
methods available to encourage a landscape that is both accessible and sustainable.
6Belisle, Francis. “Wildlife Use of Riparian Vegetation Buffer Zones in High Voltage Powerline Rights-of-
Way in the Quebec Boreal Forest.” 7th International Symposium on Environmental Concerns in Rights-of-
Way Management, 1999; Confer, John L. “Management, Vegetative Structure and Shrubland Birds of
Rights-of-Way,” 7th International Symposium on Environmental Concerns in Rights-of-Way Management,
1999; CVPS. “Central Vermont Public Service Corporations 2006 Strategy; T&D Forestry,”’ Rutland,
VT, 2006; Niering, William A. “Roadside Use of Native Plants: Working with Succession, An Ecological
Approach in Preserving Biodiversity.” Roadside Use of Native Plants:
http://www.environment.fhwa.dot.gov/ecosystems/vegmgmt_rdsduse.asp.
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In our IVM program, chemical controls are an important method to achieve long
term vegetation control. Herbicides control the entire plant, including the root system.
Eliminating the ability of the treated plants to return may allow compatible plants to take
over the space resulting in a reduction of incompatible plants to work next cycle.
This is achieved by scheduling herbicide applications to sustain acceptable vegetation
control at minimal application rates, frequency, and results in a reduction of herbicide
applied over time.7 This reduces environmental impacts and the amount of manpower
and equipment required to manage the ROW. This is a cost savings over multiple cycles
as well as reducing the potential of unintended equipment leaks or damages from
equipment.
The herbicide formulations are applied selectively and by low-volume methods
that dry quickly on the plant surface, this reduces the potential for off-target exposure.
Additionally, anti-drift adjuvants that can be adjusted to accommodate changes in wind
velocity are included in all foliage applications to further limit the likelihood of
unintentional exposure to non-target organisms. Applications are not made in situations
when there is a reasonable expectation that herbicides will drift from the targeted
vegetation, or during measurable precipitation.
The pesticide program of the Massachusetts Department of Agricultural
Resources (MDAR) established a Sensitive Area Material List to help reduce the
potential of any negative impact using herbicides in sensitive areas defined in 333 CMR
11.04. All the herbicides on this list have gone through extensive testing to be considered
for registration by the Environmental Protection Agency (EPA). Before being included
on the Sensitive Area Materials List, they go under further scrutiny by MDAR and
Massachusetts Department of Environmental Protection (MassDEP). Eversource’s
herbicide program has only used herbicides on the MDAR Sensitive Area Materials List:
https://www.mass.gov/service-details/rights-of-way-sensitive-area-materials-list
Selective herbicides applications used according to the label do not adversely affect
wetland plant composition or function according to the study cited in the Massachusetts
Department of Food and Agriculture (DFA) Decision Concerning The Wetland Impact
7Utility Transmission Forestry Herbicide Use Summary Records; Nowak & Abrahamson.
18
Study Conducted Pursuant to 333 CMR 11.04(4)(c)(2)8 (Appendix 7). According to the
1989 study by Environmental Consultants, Inc. quoted in the Decision, mechanical
vegetation control techniques result in significantly greater impact on wetland
composition and function.
Herbicide applications can be more selective than mechanical treatment methods.
Selective herbicide applications encourage plant species diversity when used to target
only incompatible vegetation. They offer selectivity and can be used to encourage
certain types of plants; for example, broadleaf vegetation can be controlled with little or
no impact to grasses.
A continual cycle of selective herbicide applications as part of an IVM
program, therefore, promotes low-growing plant communities while reducing the
density of incompatible species and reduces the herbicide use rates over time.9
Selective herbicide applications can be much less destructive than mowing to
nesting sites and the vegetation necessary for food and cover. Minor site disturbance is
associated with selective herbicide applications. This is not to say that mowing is not a
significant component in an IVM program. Both control methods need to be used in
combination with hand cutting techniques to cover all situations. In fact, thoughtful,
carefully planned, selective herbicide applications in combination with mechanical
controls, where appropriate, promote wildlife habitat by encouraging plant species
diversity.10
8 DFA is now MDAR.
9 John Gwozdz, Lewis Payne, Kendra Gorski, and Jim Kooser 2015. Herbicide Use Rates over Four Treatment Cycle: Proof the
IVM tool is working Environmental Concerns in Rights-of-Way Management, 11th International Symposium, Halifax, Novia
Scotia.
10A brief list of examples includes W.C. Bramble and W.R. Burns. “A long-term ecological study of game
food and cover on a sprayed utility right-of-way.” Bulletin No. 918, Purdue University (1974):16; Yahner.
“Wildlife Response to More than 50 years of Vegetation Maintenance on a Pennsylvania U.S., Right-of-
Way”: 123; James S. Marshall and L.W. Vandruff. Impact of Selective Herbicide Right-of-Way Vegetation
Treatment on Birds. Environmental Management 30(6) (December 2002): 801-806.
19
Herbicide application equipment that is well maintained incorporating the most
up-to-date features and the requirement that licensed contractors apply herbicides per
label instructions minimizes environmental site damage. Herbicides, particularly when
applied selectively by low-volume methods, dry quickly on the plant surface, thereby
significantly restricting the greatest potential for dermal exposure. The use of anti-drift
adjuvants in all foliage applications that can be adjusted to accommodate changes in wind
velocity further limit the likelihood of unintentional exposure to non-target organisms.
The selection of the herbicides coupled with the appropriate treatment methods is
made with consideration given to the environmental sensitivity of a ROW or site within a
ROW. For example, most conifers which do not re-sprout like hardwoods, are generally
not treated since herbicide is not necessary for control.
The herbicides, applications and other treatment methods used on any given
ROW are selected based on site sensitivity, species composition and density. Herbicides
will not be used in certain areas if site sensitivity, regulations, new restrictions, or species
composition or height require otherwise. Eversource chooses the most appropriate
treatment methods to meet its goals, objectives, and obligations. The most
responsible solution is to use all three components of IVM where appropriate.
As discussed under Section 4, Integrated Vegetation Management, a consistent
program of using herbicide is essential to effective management of the ROW and to
reducing the quantity of herbicide use over time.
Eversource began implementing an IVM system-wide program including
mechanical and chemical methods in 2003. Under this program, herbicide was applied
to target plants on a 4-year cycle at an average rate per acre of applied herbicide mixes at
approximately 7 gallons per acre which may contain active herbicide of between 3% and
10% depending on the mix for the target plant species. For ROWs that had a program of
a consistent 4-year cycle, incompatible woody stems were reduced, and a more diverse
and desirable understory of low growing vegetation was established. By 2022, the
average rate of applied herbicide to maintain these ROWs was reduced to 3-5 gallons per
acre.
20
Herbicide application on the Cape & Vineyard ROWs was stopped in 2009 and
only mechanical methods were used. Due to the cessation of chemical management,
the initial rates of herbicide were expected and did revert to an application rate closer
to the 7 gallons per acre due to the higher stem density of incompatible plants. Plants
that were controlled by mechanical methods and that continue to have a viable root
system re-sprouted with multiple shoots and have spread vegetatively
When the herbicide treatment cycle is consistent, there is a reduction in the
targeted (incompatible) plants and the need for both herbicide and mechanical
treatment is reduced. Over time, with a 4-year cycle of consistent application, the
amount of herbicide required to maintain ROW levels off to a minimum amount. The
expectation for the Cape and Vineyard would be that, over time, with a consistent,
uninterrupted cycle of herbicide treatment, incompatible plant populations will be
reduced, and the per acre rate of application will be reduced. With less incompatible
vegetation, mechanical controls can be concentrated on side pruning and removing
trees at the easement/fee edges of the ROW.
`
7. DEFINITION, IDENTIFICATION AND TREATMENT OF
SENSITIVE AREAS
Per 333 CMR 11.02, sensitive areas are "any areas within rights-of-way...in which
public health, environmental or agricultural concerns warrant special protection to further
minimize risks of unreasonable adverse effects." They include, but are not limited to, the
following:
Water Supplies
- Zone I’s
- Zone II’s
- IWPA’s (Interim Wellhead Protection Areas)
- Class A Surface Water Sources
- Tributaries to a Class A Surface Water Source
- Class B Drinking Water Intakes
- Private Wells
21
Surface Waters
- Wetlands
- Water Over Wetlands
- The Mean Annual High -Water Line of a River
- The Outer Boundary of a Riverfront Area
- Certified Vernal Pools
Cultural Sites
- Agricultural Areas
- Inhabited Areas
Wildlife Areas
- Certified Vernal Pool Habitat
- Priority Habitat
Sensitive areas consist of no-spray areas in which herbicide use is prohibited,
limited spray areas, and areas that require sensitive area restrictions. Protecting these
environmentally sensitive sites is accomplished by establishing limited spray and no-
spray areas and treatment restrictions based on the sensitivity of each site and the
requirement to minimize any unreasonable adverse impacts within that area (See
Appendix 5).
The herbicides included in the Herbicides Recommended for Use in Sensitive
Areas List (Sensitive Area Materials List) will be applied in limited spray areas according
to the application restrictions in 333 CMR 11.04 or in the case of Priority Habitat,
approval of the Yearly Operation Plan (YOP) by the Natural Heritage and Endangered
Species Program (NHESP) of the Massachusetts Department of Fisheries and Wildlife.
A current copy of the Sensitive Areas Materials List and MDAR approved active
ingredient fact sheets are available at:
https://www.mass.gov/service-details/rights-of-way-vegetation-management-vmps-yops-
and-notices
IDENTIFICATION OF SENSITIVE AREAS
Sensitive areas can be divided into two additional categories that help identify and
treat them: “readily identifiable in the field” and “not readily identifiable in the field.”
Readily identifiable in the field areas will be identified, marked, and treated when
appropriate, marked according to all applicable restrictions listed in 333 CMR 11.00. Not
22
readily identifiable in the field areas will likewise be marked and treated when
appropriate, but they are identified in the field using data marked on maps and collected
in the YOP and notification processes.
• Sensitive areas usually identifiable in the field, include but are not limited to
surface water, some private and public water supplies, wetlands, inhabited and
agricultural areas.
• Sensitive areas not usually identifiable in the field, including, but are not limited
to designated public surface water supplies, public ground water supplies, some
private drinking supplies, the first 400 feet of water supply tributaries, certified
vernal pools, and Priority Habitat of State-listed Species identified by NHESP.
As appropriate, therefore, sensitive areas will be identified and when necessary,
marked in the field by Eversource staff, an experienced vegetation management treatment
crew point person, individuals trained in the identification of sensitive areas that require
the use of GIS (geographic information systems) and GPS equipment, and/or by a
NHESP approved botanist trained in the delineation of state-listed species.
Eversource and contractor personnel assigned the task of identifying sensitive
areas in the field will use the following sources and methods:
• Massachusetts Department of Environmental Protection (MassDEP) water
supply maps /GIS mapping layers available through MassGIS. MassDEP does
not regulate private wells. However, MassDEP maintains thousands of entries
in the Well Driller Database (which includes private drinking water wells), adds
wells, makes updates as needed and has been implementing the well location
project which confirms and improves the locational accuracy of private
wells. The well driller database is available to the public through Mass. EEA’s
portal at https://www.mass.gov/service-details/well-database
• MDAR records of identified private wells along the ROW.
• Correspondence, meetings, and input from municipalities within the forty-five-
day YOP and twenty-one-day municipal right-of-way notification letter
(including Board of Health, Conservation Commission, Public Water Supplier
and Select Board/Mayor/Town Administrator) review and comment periods and
the 48-hour newspaper notification (under 333 CMR 11.06 & 11.07 and Chapter
85 of the Acts of 2000).
• Correspondence, meetings, and input from Eversource's abutter and/or
landowner notification procedure, as applicable.
• Eversource’s maps, records, and institutional knowledge.
• Any additional pertinent information that becomes available during the YOP
23
process and throughout the five years of this VMP.
• A point person who verifies identified sensitive areas and any additional areas that
may require special precautions.
• United States Geological Survey (USGS) topographical maps.
• Information from contractor’s knowledge and records.
• Information from MassGIS.
• Confidential information from NHESP.
• A copy of the YOP and VMP.
• Treatment crew(s) are required to have the following references on the job site to
help identify sensitive areas:
Topographical maps (electronic or paper)
Copy of YOP
Any additional information that may become available.
Maps are a resource and a tool for both the public and the vegetation management
crews, therefore, they contain the data needed to identify, mark, and treat sensitive areas
appropriately.
Maps included in the YOP are updated every year as new data becomes available.
Some sensitive areas are contained on the base USGS topographic maps such as
applicable Wetland Resource Areas (Rivers, Wetlands, etc.). The most current data
available through MassGIS such as public water supplies, certified vernal pools, and any
data that Eversource has collected to date on items such as private wells are then added
on top of the USGS data. At the time of treatment, additional sensitive areas will be
added to the maps utilized by Eversource’s vegetation management contractors. Please
note that to enable any viewer to see the essential information on the maps, Zone II's and
other limited spray areas are not mapped in areas where Eversource only uses herbicides
on the MDAR Rights-of-Way Sensitive Area Materials List.
The locations of the Priority Habitats of state listed species as regulated by the
Natural Heritage Endangered Species Program (NHESP) of the Division of Fisheries &
Wildlife are only included on field maps to contractors who sign a confidentiality
agreement expressly for this purpose. A map layer of Priority Habitats is available to the
general public at http://www.mass.gov/anf/research-and-tech/it-serv-and-
support/application-serv/office- of-geographic-information-massgis but it is neither
24
specific to areas of concern for herbicide applications nor does it include data on the
individual species since the exact location and details of their habitat is protected.
CONTROL STRATEGIES FOR SENSITIVE AREAS
Mandated sensitive areas will be treated following the restrictions in applicable
state and federal regulations. Eversource also reserves the right to designate additional
areas as areas that require special treatment considerations including, but not limited to,
landowner agreements, visual or environmental impact considerations, and other
considerations that arise during the treatment cycles.
Treatments in all sensitive areas will follow the operational guidelines and
restrictions listed above, as well as the guidelines described in the Sensitive Area Table in
Appendix 5.
Wetlands
Pursuant to 333 CMR 11.04 (4) (c) (2), based upon the results of two ROW
wetland impact studies (see appendix 5), the MDAR in consultation with the
Department of Environmental Protection and the Rights-of-Way Advisory Panel,
made a determination that herbicides, when used at various utilities including electric
lines, under the guidance of an IVM program and other conditions as set forth in the
determination, have less impact on wetlands than mechanical only techniques.
Therefore, in accordance with the conditions of the determination, Eversource will
selectively apply herbicides to wetland sites, except within ten feet of standing and
flowing water and to conifers which will be cut (Appendix 5).
Public and Private Water Supplies
A Sole Source Aquifer (SSA) is an aquifer that has been designated by the United
States Environmental Protection Agency (EPA) as the sole or principal source of
drinking water for an area. By definition, SSA is an aquifer that supplies at least 50%
of the drinking water consumed in the area overlying the aquifer. As of August 2008,
EPA Region 1, New England Office recognizes the Cape & Vineyard SSA as
authorized by Section 1424(e) of the Safe Drinking Water Act of 1974 (Public Law
93-523, 42 U.S.C. 300 et. seq). Eversource is aware of the nature and value of local
ground water resources and complies with regulations to protect the resource.
25
Appropriate sources and references will be consulted to determine the location of
public and private water supplies. Eversource’s YOP maps will include all known
public and private water supplies at the time of printing using the sources listed
above, and the mapping information used by contract treatment crews will be updated
as necessary during the treatment cycle.
To aid in the public and private water supply identification process, under 333
CMR 11.01(3)11, Eversource requests that during the various federal, state, and
voluntary notification processes and during the treatment cycle, that public and
municipal agencies and private entities and individuals share information on new or
unidentified public and private water supplies.
Identified private drinking supplies within one hundred feet of a ROW are
included in our permanent records and maps, and landowners are encouraged to
post signs on the edge of the ROW to help identify private water supplies (the no-
spray treatment area is fifty feet from a private well).
A point person will patrol the ROW to verify sensitive areas and buffers are
appropriately measured and when applicable flagged and recorded for permanent
record.
Massachusetts Endangered Species Act
Eversource recognizes the importance of the Massachusetts Endangered Species
Act, M.G.L.C. 131 A, and its significance to ROW vegetation management.
Eversource will comply with all applicable portions of this Act and the regulations
promulgated thereunder. Eversource will also follow the rules and prohibitions
directed at human activities which “Take” or alter their Significant Habitat (as of this
printing there are no designated Significant Habitat in Massachusetts on Eversource
ROW or statewide).
11333 CMR 11.01(3): “[The Specific goals of 333 CMR 11.00 are to] Ensure ample opportunity for public
and municipal agency input on potential impacts of herbicide application to rights-of-way in
environmentally sensitive areas.”
26
321 CMR 10.14, Massachusetts Endangered Species Act Regulations, Part II
Exemptions and 333 CMR 11.04(3) (a-c) exempts utility ROW vegetation
management from the permit process under the following conditions:
(12) The management of vegetation within existing utility rights-of-way provided
that the management is carried out in accordance with a vegetation management
plan approved in writing by the Division prior to the commencement of work for
which a review fee shall be charged, the amount of which shall be determined by
the commissioner of administration under the provisions of M.G.L. c.7, § 3B…
[and for roadside distribution lines]
(6) installation, repair, replacement, and maintenance of utility lines (gas, water,
sewer, phone, electrical) for which all associated work is within ten feet from the
edge of existing paved roads.
To comply with exemption 10.14(12), Eversource will submit this VMP and
YOPs to the NHESP for review.
The NHESP has delineated areas as Priority Habitat based on the "Best Scientific
Evidence Available" to protect State-listed species from a "take."
Under the approval process, details about the Priority Habitat of state-listed species
that might be affected by our activities and management recommendations are shared
with Eversource under strict confidentiality agreements.12
Using this data and best management practices, Eversource and contract personnel
will follow the appropriate vegetation management treatment methods within these
sensitive areas taking all practical means and measures to modify ROW vegetation
management procedures to avoid damage to state-listed species and their habitat.
To identify Priority Habitats, Eversource personnel, NHESP approved review
botanists and vegetation management crews must use proper identification
procedures. Contractors are, therefore, required to train their personnel to recognize
the location of Priority Habitats using one of the following tools: paper maps, GPS
coordinates and/or GIS systems.
______________________
12A map layer of Priority Habitat is available to the general public at http://www.mass.gov/anf/research-
and-tech/it-serv-and-support/application-serv/office-of-geographic-information-massgis , but it is neither
specific to the areas of concern for herbicide applications nor does it have detailed data on the species of
concern; the exact location and details of their habitat is kept confidential for their protection.
27
8. OPERATIONAL GUIDELINES FOR APPLICATORS RELATIVE TO
HERBICIDE USE
Eversource relies on independent vegetation management contractors and requires
that they comply with all applicable federal and state laws and regulations. This VMP,
the YOPs and information in the notification documentation are a part of the operational
guidelines for applicators relative to herbicide use. Therefore, according to the
regulations, at a minimum, the contractor’s application crews shall have a copy of the
YOP accessible at the work site.
In addition to the guidelines contained in other sections of the VMP, this section
sets forth the general operational guidelines for vegetation management.
Eversource will alter or add to these guidelines based on potential future changes
or additions to state and federal regulations that apply to herbicide applications and all
changes or additions must be approved by MDAR.
EVERSOURCE PERSONNEL
The following individual is responsible for monitoring, supervising, and
coordinating vegetation management programs (Eversource may direct
contractors to communicate with other Eversource personnel):
William Hayes, Senior Supervisor
Eversource Energy,
Transmission Vegetation Management
247 Station Drive, SW-1036
Westwood, MA 02090-9230
781-441- 3932 (office)
Eversource arborist(s) will inform the contractor which ROW will be treated, the
range of treatment dates and any other specification required to complete the job.
Eversource will provide ROW maps with treatment restriction lists and written
instructions outlining any special treatment considerations or instructions.
Contractors will notify the Eversource company representative(s) of any questions or
complaints from the public and/or government agencies that relate to ROW
vegetation management. Eversource will deal with these complaints or questions in a
timely fashion.
28
CONTRACTOR SAFETY, CONTRACT AND LEGAL COMPLIANCE GUIDELINES
• Contractors must provide qualified, personnel who have been trained to recognize
and identify compatible and incompatible vegetation and are knowledgeable in
the safe and proper use of both mechanical and chemical vegetation management
techniques.
• All personnel applying herbicides in Massachusetts must hold a pesticide
applicator license and must work under the on-site supervision of a certified
applicator, with a Category 40 certification.
• Herbicides must be handled and applied only in accordance with label instructions.
• Mixing will be done according to University of Massachusetts Extension Pesticide Mixing and
Loading Best Management Practices (BMP).
• Contractors must not start work without the appropriate maps, restriction
lists, landowner notifications and mixing rate instructions.
• Contractors must follow the latest revisions of all industry standards including,
but not limited to all applicable safety standards under the Occupational Safety
and Health Act (OSHA) including 1910.269, Electric Power Generation,
Transmission, and Distribution; ANSI Z133 & ANSI 300 standards, and
Eversource Safety Procedures.
• All contract personnel must follow label instructions regarding Personal
Protective Equipment (PPE).
• Applicators must immediately cease operations if adverse conditions or
other circumstances warrant.
• Access to a ROW will be using established roadways whenever possible.
• All gates shall be closed.
• Care shall be exercised to prevent the rutting or destruction of roadways, fields,
or any other form of access.
• No litter of any kind will be left on the ROW or adjoining land.
CONTRACTOR DAILY TASKS
• Call the appropriate Eversource personnel.
• In compliance with both regulations and Eversource policy, the contractors’
foreman or senior crew member must complete daily vegetation management
reports that include:
Date, name, and address of vegetation management contractor(s).
Identification of site or work area.
List of crew members.
Type of equipment and hours used, both mechanical and chemical
29
Method of application and description of incompatible vegetation
Amount, concentration, product name of herbicide(s), adjuvants and
dilutants (EPA registration numbers must be on file).
Weather conditions.
Notation of any unusual conditions or incidents, including public
inquiries.
Recording and/or verification of sensitive areas on ROW maps.
• All required forms will be distributed to the contractors by the Eversource
representative(s).
• Eversource request that contractor(s) call if they see a hazard tree.
• Contractors must follow the Specifications noted in the Request for Proposal.
EQUIPMENT
• Eversource will not dictate the exact equipment to be used by the contractors,
instead, all equipment shall be of adequate design to produce professional quality
results.
• Equipment must be maintained in good working condition, including being
calibrated as appropriate.
• Care and common sense shall be exercised when moving vehicles and equipment.
LANDOWNERS/ABUTTERS
Landowners/abutters are individuals whose property is either under Eversource's
ROW easements/fee land and/or abuts the ROW.
• Landowners will always be treated with courtesy and respect.
• If a landowner demands vegetation maintenance cease, the contractor should
remove the crew and equipment off the property, inform the appropriate
Eversource representative as soon as possible.
• When addressing complaints from a landowner, or other concerned
person, notice will be given to the appropriate authorities at MDAR.
RESULTS
• Vegetation management programs must result in a control level on target
vegetation stem count on a per span basis of at least 90% under 6 feet, and 100%
6 feet and greater, or the contractor may be held responsible to re-work areas that
do not meet required results.
• Vegetation management crews will exercise care to ensure low-growing
30
compatible vegetation and other non-target organisms are not unreasonably
affected by the application of herbicides.
• Unreasonable site damage or destruction during any phase of the vegetation
management operation by the contractor, his agents, or employees, will be
repaired by said contractor to Eversource's satisfaction. Eversource evaluates
claims promptly based upon an internal investigation and the information
provided. Once the investigation is complete, Eversource will contact the
claimant with the results.
9. ALTERNATIVE LAND USES
Wherever practical, as determined by the Senior Arborist or Eversource
management, Eversource will cooperate with landowners through whose property
Eversource owns easements, to facilitate "alternative land use" practices by the
landowner's that may reduce or eliminate the need for vegetation management by
Eversource.
Acceptable uses may include but are not limited to an approved lawn, garden, or
crops with compatible species of plants, golf courses, parking lots, approved by
Eversource Energy. Any alternative land use proposed by a landowner within an
electrical transmission easement must be reviewed by Eversource. Eversource will
review a properly submitted proposal and consider conditional approval. The submittal
should be addressed to: Supervisor, T & D Rights and Survey, Eversource Energy,
Eastern MA, 247 Station Drive, Mail Stop SE210, Westwood, MA 02090. Any approval
by the Company is given in the form of a written license only and with the understanding
that Eversource’s easement rights are in no way diminished nor does the company
assume any liability.
31
10. REMEDIAL SPILL AND EMERGENCY PLAN
Eversource contracts with independent, professional, certified herbicide
applicators that are responsible for the containment, clean up and reporting of chemical
spills or accidents. The following is a guide to the information sources that, according to
various regulations, must be available to the treatment crew in the event of a chemical
spill or emergency.
TYPES OF CHEMICAL SPILLS THAT REQUIRE ACTION
Chemicals include, but are not limited to the following:
• Herbicides
• Bar and Chain Oil
• Motor & Hydraulic Oil
• Diesel Fuel
• Gasoline
• Title 3 Hazmat Materials
REQUIRED SPILL RESPONSE EQUIPMENT
As a minimum, the ROW crew shall have available on the job site:
• VMP and YOP with emergency contact lists
• Safety Data Sheets and product labels
• Product Fact Sheets
• Appropriate absorbent material such as “speedi dri” or “soak up”
• Shovel
• Broom
• Flagging
• Leak proof container
• Heavy-duty plastic bags
PERSONAL CONTACT
In the event of Personal Contact with hazardous chemicals:
• Wash affected area with plenty of soap and water
• Change clothing which has absorbed hazardous chemicals
• If necessary, contact a physician
• If necessary, contact the proper emergency services
• If necessary, follow the procedures for Major or Minor Spills as outlined below
• Avoid breathing the fumes of hazardous chemicals
32
TECHNICAL REFERENCE MATERIALS
A. Herbicide Information
1. Product Label
2. Product Safety Data Sheet (SDS)
3. Product Fact Sheet, if available
B. Table 1. Herbicide Manufacturers:
MANUFACTURER TELEPHON
E NUMBER
SPECIAL
INSTRUCTIONS
Albaugh Inc. (800) 247-8013
BASF Corporation (800) 832-4357
ENVU and Bayer Environmental Science (800) 334-7577
Corteva AgriScience (800) 992-5994
Nufarm (877) 325-1840
Rainbow Treecare (877) 272-6747
C. Table 2. State Agencies:
STATE AGENCY TELEPHONE
NUMBER
SPECIAL INSTRUCTIONS
MDAR, Pesticide Bureau (617) 626-1700 A.S.A.P. (within 48 hours)
Massachusetts Department of
Environmental Protection,
Emergency Response Section
DEP 24 Hour
Contact: (888) 304-1133
For emergencies involving
reportable quantities of material
(listed in the Massachusetts
Contingency Plan, 310 CMR
40.0000); required info:
City/town, street address, site
name (if applicable), material
Southeast Region:
(508) 946-2700
MA Department of Public
Health, Bureau of
Environmental Health’s
Environmental Toxicology Program
(617) 339-8351
Massachusetts Poison
Information Centers
(800) 682-9211 For medical emergencies
involving suspected or known
pesticide poisoning symptoms
33
D. Table 3. Emergency Services:
EMERGENCY SERVICE TELEPHONE
NUMBER
SPECIAL
INSTRUCTIONS
Massachusetts State Police,
Central Office
(617) 566-4500 or 911
Local Fire / Police Dept. 911
ChemTrec (800) 424-9300
Clean Harbors (800) OIL-TANK
Pesticide Hotline (800) 858-7378 PST: 6:30 am – 4:30 pm, Web: www.NPIC.orst.edu
E. Eversource's contact in the case of a spill or accident is:
Eversource System Control:
Electric Ops North, (617) 541-7825
Electric Ops South, (617) 541-7858
F. Table 4. Local Emergency Numbers:
Emergencies Services for All Municipalities: 911
(To be filled out with the appropriate towns and included in the YOPs)
Town Board of Health Town/City Hall Town Board of Health Town/City Hall
CLEAN-UP PROCEDURES
Education and attention will constantly be directed at accident and spill prevention;
however, the following is a guideline in the event of an unfortunate incident:
REPORTABLE SPILLS (Spills of reportable quantity of material): FOLLOW STEPS 1-9
NON-REPORTABLE SPILLS: FOLLOW STEPS 1-4, 5-9 as appropriate & contact the
EVERSOURCE representative.
34
G. Table 5: HERBICIDE SPILL CHECK LIST
Order ACTION Done
(√)
1 Use all PPE as directed by product label or SDS.
2 Cordon-off spill area to unauthorized people and traffic to reduce the spread and exposure of the spill
3 Identify source of spill and apply corrective action, if possible, stop or limit any additional amounts of spilled
product.
4 Contain spill and confine the spread by damming or diking with soil, clay, or other absorbent materials.
5 Report spills of “reportable quantity" to the Mass. Dept. of Environmental Protection and MDAR:
MDAR, Pesticide Bureau (617) 626-1700
Massachusetts Department of Environmental
Protection Emergency Response Section
MassDEP 24 Contact Number: (888) 304-1133
Southeast Region: (508) 946-2700
6 If the spill cannot be contained or cleaned-up properly, or if there is a threat of contamination to any bodies of
water, immediately contact any of the following applicable emergency response personnel:
local fire, police, rescue 911
Eversource: Operations (617) 541-7821
Eversource Transmission: William Hayes (781) 441-3932
Eversource Distribution - Paul Sellers (508) 957-4603
Product Manufactures
1. Albaugh Inc. (800) 247-8013
2. BASF Corporation (800) 832-4357
3. ENVU and Bayer Environmental Science (800) 334-7577
4. Corteva AgriScience (800) 992-5994
5. Nufarm (877) 325-1840
6. Rainbow Treecare (877) 272-6747
7. Chemtrec (800) 424-9300
8. additional emergency personnel
If there is a doubt as to who should be notified, contact State Police, Central Office (617) 566-4500 or 911
Remain at the scene to provide information and
assistance to responding emergency clean-up crews
Refer to the various sources of information relative
to handling and cleanup of spilled product
If possible, complete the process of “soaking up” with
absorbent materials
7 Sweep or shovel contaminated products and soil into leak proof containers for proper disposal at approved location
8 Spread activated charcoal over spill area to inactivate any residual herbicide
35
11. Identification and Qualification of Individual Developing
and Submitting the Plan
Mr. William Hayes is responsible for preparing and submitting this VMP,
supervision of the IVM program and overall supervision for development and
implementation of the VMP:
William N. Hayes Jr., Senior Supervisor
Eversource Energy
Transmission Vegetation Management
247 Station Drive, SW-1036
Westwood, MA 02090-9230
781-441- 3932 (office)
He is ultimately responsible for preparation, implementation of and compliance with this
VMP and YOP’s to be submitted annually. He is responsible for implementing the
vegetation management programs best practices on transmission, and distribution
systems. He develops and evaluates methods for vegetation management to ensure
transmission and distribution system reliability follows regulations and standards.
Provide work scheduling, prescription of herbicides and application methods,
procurement of necessary permits, municipal notifications, contractor selection,
provision of technical expertise and liaison between Company right-of-way easement
landowners, neighbors, local and state officials and other interested parties and field
supervision of vegetation management contractors and Eversource arborists.
His qualifications extend from education to over 30 years of work related to utility
arboriculture. He has a Bachelor of Science, Majoring in Forestry Management with
concentration in Arboriculture/Urban Forestry from the University of Massachusetts.
Credentials include Massachusetts Certified Arborist, International Society of
Arboriculture Certified Arborist, Massachusetts Category 40 Pesticide License,
Consumers Power Co. Certified Basic Tree Trimmer. He is a member of the
Massachusetts Arborist Association, Massachusetts Tree Wardens & Foresters
Association, Utility Arborist Association, and the International Society of Arboriculture.
APPENDIX 1:
EVERSOURCE ENERGY
CAPE COD AND MARTHA’S VINEYARD
(BARNSTABLE AND DUKES COUNTIES)
ELECTRIC SYSTEM MAP
APPENDIX 2:
EVERSOURCE ENERGY
CAPE COD AND MARTHA’S VINEYARD
(BARNSTABLE AND DUKES COUNTIES)
LIST OF MUNICIPALITIES
MUNICIPALITIES
BARNSTABLE EDGARTOWN SANDWICH
BOURNE FALMOUTH TISBURY
BREWSTER HARWICH TRURO
CHATHAM MASHPEE WELLFLEET
DENNIS OAK BLUFFS YARMOUTH
EASTHAM ORLEANS
APPENDIX 3:
333 CMR 11.00
https://www.mass.gov/regulations/333-CMR-1100-rights-of-way-management
APPENDIX 4:
CHAPTER 132B
HTTPS://MALEGISLATURE.GOV/LAWS/GENERALLAWS/PARTI/TITLEXIX/CHAPTER132B
APPENDIX 5:
SENSITIVE AREA TABLE
CONTROL STRATEGIES FOR SENSITIVE AREAS
Sensitive Area No-Spray and
Limited Spray
Areas (feet)
Control Method Restriction
Code
Public Ground Water
Supplies
400' Mechanical Only None
Primary Recharge Area Designated buffer
zone or 1/2 mile radius
Mechanical,
Recommended Herbicides*
24 months
Public Surface Water
Supplies (Class A & Class B)
100' Mechanical Only None
100'-400' Recommended Herbicides 24 months
Tributary to Class A Water
Source, within 400' upstream
of water source
100' Mechanical Only None
100'-400' Recommended Herbicides 24 months
Tributary to Class A Water
Source, greater than 400'
upstream of water source
10' Mechanical Only None
10'-200' Recommended Herbicides 24 months
Class B Drinking Water
Intake, within 400' upstream
of intake
100' Mechanical Only None
100'-200' Recommended Herbicides 24 months
Private Drinking Water
Supplies
50' Mechanical Only None
50'-100' Recommended Herbicides 24 months
Surface Waters 10' Mechanical Only None
10'-100' Recommended Herbicides 12 months
Rivers 10' from mean annual
high-water line
Mechanical Only None
10'-200' Recommended Herbicides 12 months
Wetlands 100' (treatment in
wetlands permitted up
to 10' of standing
water) *+
Low-pressure Foliar, CST,
Basal
Recommended Herbicides
12 months
Inhabited Areas 100' Recommended Herbicides 12 months
Agricultural Area (Crops,
Fruits, Pastures)
100' Recommended Herbicides 12 months
Certified Vernal Pools 10' Mechanical Only when
water is present
None
Certified Vernal Pool Habitat 10'-outer boundary of
habitat
No treatment without written approval per
321 CMR 10.14(12)
Priority Habitat No treatment without written approval per 321 CMR 10.14(12)
Restrictions “24 Months": A minimum of twenty-four months shall elapse between applications
“12 Months": A minimum of twelve months shall elapse between applications
*Massachusetts recommended herbicides for sensitive sites
+Per the DFA Decision Concerning the Wetlands Impact Study for utilities per 333 CMR 11.04(4)(c)(2).
APPENDIX 6:
PREFACE TO 310 CMR 10.00
https://www.mass.gov/regulations/310-CMR-1000-wetlands-protection
APPENDIX 7:
WETLANDS STUDY
C OMMONWEA LTH O F M ASSAC HUSETTS
EXECUTIVE O FFICE OF ENVIRONMENT AL AFF AIRS
D EPART MENT OF FOOD AND AGRICULTURE
100 CAMDRIDGE ST., BOSTON. MA 02202 617-727-3000 FAX 727-7235
WI Li.JAM F. WE LD
Gov ernor
ARGEO PAUL CE LLUCCI
LL Gove rno r
Decision Concerning
The Wetland Impact Study Conducted
Pursuant to 333 CMR 11.04(4)(c)(2)
TRUDY CO XE
S ecre tary
JO NAT HAN L. II EALY
Co m miss ioner
PUBLIC UTILITY VEGETATION
MANAGEMENT PROGRAM FINDING
Background
The Rights of Way Management (ROW) Regulations (333 CMR 11:00)
promulgated in 1987 prohibit the use of herbicides to control vegetation along utility
right of ways on or within ten (10) feet of a wetland unless the following conditions
are met:
1. Submission of a study, the design of which is subject to prior review
and approval of the Departments of Food and Agriculture and
Environmental Protection, evaluating impacts of proposed vegetation
management programs on wetlands; and
2. A finding by the Department, after consultation with the Advisory
Committee, that the proposed vegetation management program will
result in less impacts to the wetland than mechanical control.
3. Notwithstanding the above, no herbicides shall be applied on or within
ten feet of any standing or flowing water in a wetland.
On April 28, .1988, The Departments of Food and Agriculture and
Environmental Protection approved the scope of the study. In the fall of 1989,
Environmental Consultants, Inc. submitted to the Department of Food and
Agriculture the study entitled, "Study of the Impacts of Vegetation Management
Techniques on Wetlands for Utility Rights-of Way in the Commonwealth of
Massachusetts", dated June 1989. The Department consulted with the Vegetation
Management Plan (VMP) Advisory panel at their November 15, 1989, December
7, 1989 and August 1, 1991 meetings.
1
-
2
3
4
5
6
7
8
9
10
APPENDIX 8:
CHAPTER 85, SECTION 10
HTTPS://MALEGISLATURE.GOV/LAWS/SESSIONLAWS/ACTS/2000/CHAPTER85
APPENDIX 9:
REFERENCES
1
REFERENCES
SENSITIVE MATERIALS LIST:
A current list of the Sensitive Area Materials List and individual Fact Sheets on these herbicides
are available at:
http://www.mass.gov/eea/agencies/agr/pesticides/rights-of-way-vegetation-management.html
SAFETY:
ANSI. American National Standard Z133. Champaign, IL: International Society of
Arboriculture, Champaign, IL, 2006.
ANSI 92-3. American National Standard 30. International Society of Arboriculture,
Champaign, IL, 2006.
Calvert, Geoffrey, Plate, D.K., Das, R., Rosales, R., Shafey, O., Tomsen, C., Male, D., Beckman,
J., Arvizu, E. & Lackovic, M. “Acute Occupational Pesticide-Related Illness in the US,
1998-1999: Surveillance Findings From the SENSOR-Pesticide Program." American
Journal of Industrial Medicine 45:14-23, 2004.
IVM and the Environment:
Askins, Robert A. Restoring North America’s Birds; Lessons from Landscape Ecology, Yale
University Press, New Haven, CT, 2000.
. “Sustaining Biological Diversity in Early Successional Communities: The
Challenge of Managing Unpopular Habitats,” Wildlife Society Bulletin 29(2) (Summer,
2001).
Belisle, Francis. “Wildlife Use of Riparian Vegetation Buffer Zones in High Voltage Powerline
Rights-of-Way in the Quebec Boreal Forest.” 7th International Symposium on
Environmental Concerns in Rights-of-Way Management, 1999.
Bramble, W.C. and Burns, W.R. “A Long-term Ecological Study of Game Food and Cover on a
Sprayed Utility Right-of-Way.” Bulletin No. 918, Purdue University, 1974:16.
Bramble, W.C; W.R. Burns; R.J. Hutnik, and S.A. Liscinsky. “Interference Factors Responsible
For Resistance of Forb-Grass Cover Types to Tree Invasion on an Electric Utility Right-
of-Way.” Journal of Arboriculture 22(2), March 1996: 99-105.
Bramble, W.C., W.R. Byrnes, and R.J. Hutnik. “Resistance of Plant Cover Types to Tree
Seedling Invasion on an Electric Utility Transmission Right-of-Way.” Journal of
Arboriculture, 16(5), May 1990.
“Central Vermont Public Service Corporations 2006 Strategy; T&D Forestry.” Rutland, VT, 2006.
Confer, John L. “Management, Vegetative Structure and Shrubland Birds of Rights-of-Way.” 7th
International Symposium on Environmental Concerns in Rights-of-Way Management,
1999.
2
Deubert. K.H. “Studies on the Fate of Garlon 3A and Tordon 101 Used in Selective Foliar
Application in the Maintenance of Utility Rights-of-Way in Eastern Massachusetts.”
Final Report prepared for New England Electric et. al.,1985.
Environmental Consultants, Inc. “Study of the Impact of Vegetation Management Techniques
on Wetlands for Utility Rights-of-Way in the Commonwealth of Massachusetts.” Final
report prepared for New England Electric et.al, 1989.
. “Determination of the Effectiveness of Herbicide Buffer Zones
in Protecting Water Quality on New York State Powerline Rights-of-Way.” Final report for
the Empire State Electric Energy Research Corporation, 1991.
Galen Guerrero-Murphy, Tim Follensbee II, and Jeff Disorda 2015.
“Best Management Practices (BMPs) for Protection of Threatened and Endangered Species
during Integrated Vegetation Management and Operations and Maintenance of Electric
Transmission Lines in Vermont.” Environmental Concerns in Rights-of-Way Management,
11th International Symposium, Halifax, Novia Scotia.
Goodrich-Mahoney, John W.; Abrahamson, Lawrence, P.; Ballard, Jennifer I.; Tikalsky, Susan
M. 8th International Symposium Environmental Concerns in Rights-of-Way
Management, 2004.
Gwozdz, John, Lewis Payne, Kendra Gorski, and Jim Kooser 2015.
“Herbicide Use Rates over Four Treatment Cycle: Proof the IVM tool is working”.
Environmental Concerns in Rights-of-Way Management, 11th International Symposium,
Halifax, Novia Scotia.
Harrison Biotech, Inc. “A Generic Environmental Impact Report on the Control of Vegetation on
Utility and Railroad Rights-of-Way in the Commonwealth of Massachusetts.” Final Report
prepared for the Department of Food and Agriculture, Commonwealth of Massachusetts,
1985.
Hickler, Matt, MA NHESP approved Review Biologist, Reports for TransCanada, National Grid,
NSTAR, Northeast Utilities under 321 CMR 10.00 Massachusetts Endangered Species
Act Regulations. (Also Reports in NH and VT), 2006-2010.
Marshall, James S. “Effects of Powerline Right-of-Way Vegetation Management on Avian
Communities.” 7th International Symposium on Environmental Concerns in Rights-of-
Way Management, 1999.
Marshall, James S. and Vandruff, L.W. “Impact of Selective Herbicide Right-of-Way Vegetation
Treatment on Birds,” Environmental Management Vol. 30, No. 6, December 2002.
Miller, R.H. 2012. Best Management Practices: Integrated Vegetation Management.
Society of Arboriculture, Champaign, IL.
National Grid USA Electric Companies. 5-Year Massachusetts VMP, 2009-2013, p. 9.
Nickerson, N.H, G.E. Moore and A.D. Cutter. “Study of the Environmental Fates of Herbicides
in Wetland Soils on Electric Utility Rights-of-Way in Massachusetts over the Short Term.”
Final Report prepared for New England Electric et.al, December 1994.
3
Neiring, W.A. and R.H. Goodwin. “Creation of Relatively Stable Shrublands With Herbicides:
Arresting Succession on Rights-of-Way and Pastureland.” Ecology 55(4), 1974.
Niering, W.A. “Roadside Use of Native Plants: Working with Succession, An Ecological
Approach in Preserving Biodiversity.” Roadside Use of Native Plants:
http://www.environment.fhwa.dot.gov/ecosystems/vegmgmt_rdsduse.asp.
Nowak, Christopher.A. and L.P. Abrahamson. “Vegetation Management on Electric
Transmission Line Rights-of-Way in New York State: The Stability Approach to Reducing
Herbicide Use.” Proceedings of the International Conference on Forest Vegetation
Management, Auburn University, April 1993.
Nowak, Christopher A. & Ballard, Benjamin D. “A Framework for Applying Integrated
Vegetation Management on Rights-of-Way.” Journal of Arboriculture 31(1) (January
2005).
Oehler, James D., ed; Darrel F. Covell, ed; Steve Capel, ed, and Bob Long, ed. “Managing
Grasslands, Shrublands and Young Forests for Wildlife; A Guide for the Northeast.” The
Northeast Upland Habitat Technical Committee. 2006.
Schaefer, Valentin. “Rights-of-Way in Support of Biological Conservation“ 7th International
Symposium on Environmental Conserns in Rights-of-Way Management, 1999.
United States Environmental Protection Agency. “Fact Sheet: Integrated Vegetation
Management.” EPA 731-F-08-010 (Oct. 2008).
University of California. “Definition of Integrated Pest Management.”
http://www.ipm.ucdavist.edu.
Vers, Frans. “The Shifting Baseline Syndrome in Restoration Ecology.” Restoration and
History: The Search for a Usable Environmental Past. Ed. Marcus Hall: 101.
Yahner, Richard H. “Wildlife Response to More than 50 years of Vegetation Maintenance on a
Pennsylvania U.S., Right-of-Way.” Journal of Arboriculture 30(2), March 2004.
. “State Game Lands 33 Research and Demonstration Project—57 years of
Continuous Study on the Shawville to Lewiston 230-kV line of First Energy (Penelec).
2009.
. “2009 Annual Report to Cooperators. Green Lane Research and
Demonstration Project: 23 Years of Continuous Study.” (2009).
EVERSOURCE ENERGY, EASTERN (Cape), MA
2023 YEARLY OPERATIONAL PLAN
MASSACHUSETTS DEPARTMENT OF AGRICULTURAL RESOURCES
INTEGRATED VEGETATION MANAGEMENT HERBICIDE PROGRAM
Submitted by:
Eversource Vegetation Management
Submitted:
MAY 24, 2023
i
SUMMARY
In compliance with the Massachusetts Department of Agricultural Resources’ Rights-of-Way
Regulations (333 CMR 11.00), this Yearly Operational Plan (YOP) informs municipalities of Eversource
Energy, Eastern (Cape) MA’s intent to utilize an integrated vegetation management plan that includes the
use of herbicides on electric rights-of-way (ROW) in 2023. Our Integrated Vegetation Management
program is outlined in our five-year Vegetation Management Plan.
This YOP identifies target vegetation; the affected rights-of-way and towns; the herbicides, rates
and methods of application; alternative control methods; the individual responsible for supervising the
OP, and the qualified contractors that will perform the application. It explains how sensitive areas; buffer
zones and sites where herbicides are either restricted or not permitted are identified, appropriately
marked, treated and protected. It addresses procedures for the mixing, handling and loading of herbicide
concentrates. Finally, it includes Herbicide Fact Sheets and Labels, a list of emergency resources and
telephone numbers, and maps marked with known Sensitive Areas.
The YOP process provides for a forty-five-day public review and comment period, in conjunction
with the twenty-one-day municipal rights-of-way notification period. These review periods give
communities an opportunity to provide information that will help identify additional areas that may
require specific precautions or protection. Finally, notice will be published in general circulation
newspapers at least 48 hours before the scheduled application.
ii
TABLE OF CONTENTS
SUMMARY i
I. INTRODUCTION 1
II. CHAPTER 132B AND 333 CMR 11.00 2
III. LOCATION OF INTENDED TREATMENT 3
IV. IDENTIFICATION OF TARGET VEGETATION 4
V. DEFINITION, IDENTIFICATION AND TREATMENT OF SENSITIVE AREAS 5
VI. PROPOSED HERBICIDE TREATMENT METHODS 8
VII. PROPOSED HERBICIDES, CARRIERS, ADJUVANTS AND RATES 10
VIII. ALTERNATIVE MECHANICAL CONTROL TECHNIQUES 13
IX. THE COMPANIES THAT WILL PERFORM THE HERBICIDE TREATMENT 14
X. INDIVIDUAL RESPONSIBLE FOR SUPERVISING THE OP 14
XI. HERBICIDE FACT SHEETS 14
XII. PROCEDURES AND LOCATIONS FOR HANDLING, MIXING AND
LOADING HERBICIDE CONCENTRATES
14
XIII. EMERGENCY RESOURCES 14
APPENDICES
APPENDIX I. MAPS
APPENDIX II. SENSITIVE AREA TABLE
APPENDIX III. HERBICIDE FACT SHEETS
APPENDIX IV. HERBICIDE LABELS
LIST OF TABLES
TABLE I. 2023 RIGHTS-OF-WAY 3
TABLE II. 2023 IVM (HERBICIDE) MUNICIPALITIES 4
TABLE III. TANK MIXES FOR LOW VOLUME FOLIAGE APPLICATIONS 10
TABLE IV. TANK MIXES FOR POISON IVY, VINES, AND INVASIVE SPECIES 12
TABLE V. TANK MIXES FOR CUT SURFACE TREATMENT (CST) APPLICATIONS 12
TABLE VI. TANK MIXES FOR LOW-VOLUME BASAL OR CUT SURFACE
TREATMENT (CST) APPLICATIONS 13
TABLE VII. HERBICIDE MANUFACTURERS 15
TABLE VIII. STATE AGENCIES 15
TABLE IX. EMERGENCY SERVICES 15
TABLE X. LOCAL EMERGENCY NUMBERS 16
1
I. INTRODUCTION
In compliance with Commonwealth of Massachusetts’ Rights-of-Way Vegetation Management
Regulations (333 CMR 11.00) Eversource Energy, Eastern MA’s Yearly Operational Plan (YOP) details
our vegetation management program for 2023. This YOP is consistent with the terms and procedures set
forth in the Eversource Energy, Vegetation Management Plan’s (VMP’s) per 333 CMR 11.05; with the
Massachusetts Pesticide Control Act (Chapter 132B); with all pertinent clauses in Chapter 85 of the Acts
of 2000; with the Massachusetts Endangered Species Act (MESA; MGL c. 131 A) and regulations (321
CMR 10.00), and with all Federal and State acts and regulations that apply to right-of-way vegetation
management.
Eversource delivers electricity to 1.3 million customers in 136 municipalities. Electricity is
transmitted over hundreds of miles of distribution and transmission rights-of-way (ROW) throughout the
western, eastern, southeastern, and cape and islands regions of Massachusetts. To ensure safe reliable
electric service, Eversource must keep these ROWs free from hazards and encroachments. In this effort,
the vegetation on the ROW corridors must be maintained at an early stage of plant succession (herbaceous
plants and shrubs).
Using the Integrated Vegetation Management Program (IVM) described in the VMP’s,
Eversource’s program is based on a 4-year selective herbicide application and where appropriate
mechanical treatment cycle. This program allows for the safe delivery of reliable electric service and
supports a healthier more diverse habitat for wildlife that depends upon early successional landscapes
(See VMP’s for further description of Eversource’s IVM program). The VMP’s can be viewed at:
https://www.eversource.com/content/residential/about/reliability/vegetation-
management/transmission-system-vegetation-management/transmission-vegetation-management-projects
2
II. CHAPTER 132B AND 333 CMR 11.00
The purpose of this chapter is to conform the laws of the commonwealth to the Federal
Insecticide, Fungicide, and Rodenticide Act, Public Law 92-516, as amended, and the regulations
promulgated there under and to establish a regulatory process in the commonwealth. The
exclusive authority in regulating the labeling, distribution, sale, storage, transportation, use and
application, and disposal of pesticides in the commonwealth shall be determined by this chapter.
(MGL 132B, Section 1)
Chapter 132b (Massachusetts Pesticide Control Act) was created to ensures a clear and uniform
set of standards for the entire Commonwealth of Massachusetts in order to protect the public from the
negative impacts that arise from fragmented, decentralized, sets of standards. In this effort, the
Commonwealth, through the Department of Agricultural Resources (MDAR) retains the sole right to
regulate the use of pesticides, including herbicides, throughout Massachusetts. MDAR takes this
responsibility extremely seriously and the regulations promulgated under Chapter 132b are stricter than
Federal standards.
The purpose of 333 CMR 11.00 is to establish a statewide and uniform regulatory process which
will minimize the uses of, and potential impacts from herbicides in right of way on human health
and the environment while allowing for the benefits to public safety provided by the selective use
of herbicides (333 CMR 11.01).
333 CMR 11.00 is the most comprehensive rights of way regulation in New England. It requires
an Integrated Pest Management (in this case IVM) approach to right of way vegetation management; the
establishment of standards and procedures to prevent unreasonable risks to humans or the environment,
and a multi-layered system of public and municipal notification that requests input about environmentally
and culturally sensitive areas. All of this is outlined in the Eversource VMPs, annual YOPs, The
Environmental Monitor Notice, 21-day notification, Public Water Supplier notification and 48- hour
newspaper notice which serve as guides for the public, state and municipal officials, vegetation
management contractors and Eversource personnel.
To ensure compliance with Chapter 132b and 333 CMR 11.00, MDAR performs routine
inspections of rights-of-way treatment crews, retains chemists, and perform further tests before approving
a limited list of herbicides approved for use in Sensitive Areas (pursuant to 333 CMR 11.04 (1)(d)).
As detailed in the VMP’s and YOP, Eversource Energy, Eastern MA’s IVM program strictly
adheres to all the requirements of Chapter 132b and 333 CMR 11.00. Eversource only retains herbicide
application treatment contractors that hold Massachusetts’ certifications and licenses to apply pesticides,
which require ongoing training to maintain. All Sensitive Areas (see section V) are treated appropriately
using either mechanical treatment methods or Commonwealth of Massachusetts recommended herbicides
for use in Sensitive Areas. In fact, Eversource only uses these recommended herbicides on the entire
length and cleared width of its ROW corridors.
Beyond the requirements of 333 CMR 11.00 and in compliance with Chapter 216 of the Acts of
2012, Eversource also notifies “abutters” (houses and businesses that abut the rights-of-way being treated
in that year) within view of the ROWs before treatments begin. Treatment contractors are required to
leave door hangers or talk personally with abutters which allow the contractor to answer site specific
questions, identify private wells and help explain the program.
3
III. LOCATION OF INTENDED TREATMENTS
In 2023 Eversource plans on completing vegetation maintenance on 1 transmission ROW as
listed in Table I. Table II is a list of municipalities where a herbicide treatment will be applied as part of
IVM.
Table I. 2023 Rights-of-Way:
Massachusetts East (EMA) Cape
ROW Segment Name
Electric Transmission Right of Way
180 EHV Canal (Bourne town line southeast) - Pilgrim Tap
Table II: List of 2023 IVM (herbicide treatment) Municipalities:
Eastern MA (EMA) Cape municipalities:
Bourne
4
IV. IDENTIFICATION OF TARGET VEGETATION FOR HERBICIDE APPLICATIONS
Pursuant to the policy and intent set forth in the Eversource VMPs, all vegetation must be removed that
obscures the ROW corridors and grows tall enough to interfere with the safe, efficient and legal operation
of an electrical power line. In the wire zone, trees and brush are targeted, and native, low growing plant
communities that have a mature height less than three feet are established. In the border zone,
incompatible trees and brush are targeted, and the growth of native trees and shrubs that have a mature
height less than 15 feet is encouraged.
The primary target is all trees’ species within the cleared width of the ROW; except in Priority
Habitats that are under the purview of the Natural Heritage and Endangered Species Program of the
Department of Fish and Game (NHESP), which will be treated on a case by case basis.
Examples of targets include, but are not limited to:
Alder Cherry Pine
Aspen Hemlock Maple
Beech Hickory Oak
Birch Locust Sassafras
There are more non-target vegetation species on an electric or gas ROW than targets. In fact,
ROWs are one of the primary early successional plant communities remaining in New England. As a
result, many plant and animal species use ROWs as their homes, feeding grounds or nurseries. Certain
plant species, therefore, are encouraged on the ROW through the use of an IVM program (excluding
invasive plant species):
• Most herbaceous growth is acceptable and encouraged
• Shrubs that mature less than 15 feet in height are only targets where due to their location or
attributes they interfere with the function of the ROW.
Certain categories of non-tree species are targets under some circumstances, because of their
location and/or their nature. Dense woody vegetation, shrubs and vines are targets where they are capable
of interfering with the inspection and maintenance of the poles, wires, and along access roads, paths and
gates which need to be kept clear, especially for emergencies.
Eversource intends to control plant species including invasive, poisonous plants and vines at their
facilities. Invasive plant species have become an increasing concern throughout Massachusetts in areas
that include ROW corridors where they can spread rapidly and move into the adjacent landscape.
Eversource plans to use herbicides to spot treat poisonous plants at sites under its ROWs identified as
having an elevated risk of posing a health hazard. This vegetation, likewise, poses a risk to the safety and
health of all individuals working on or traversing a ROW and it can impede a rapid response in an
emergency.
Examples of non-tree species considered targets, include, but are not limited to:
Autumn Olive Japanese Knot-Weed Greenbriar
Buckthorn Multiflora Rose Poison Ivy
Buckthorn Oriental Bittersweet
Hawthorne Staghorn Sumac
Honeysuckle Poison Sumac
5
V. DEFINITION, IDENTIFICATION AND TREATMENT OF SENSITIVE AREAS
Sensitive Areas are those areas within a ROW in which public health, environmental concerns or
agricultural interests warrant special protection to minimize the risk of unreasonable adverse effects.
The map(s) in Appendix I are a resource and a tool for both the public and the vegetation
management crews. They contain the data necessary to identify, mark and treat Sensitive Areas
appropriately.
The map(s) include known Sensitive Areas available at the printing of this YOP. Some Sensitive
Areas are included in the base USGS topographic maps. The most current data available through Mass
GIS such as public water suppliers, certified vernal pools, etc. and any data that Eversource has collected
to date on areas such as private wells are added on top of the USGS data. At the time of treatment, any
additional Sensitive Areas collected will be added to the maps utilized by our vegetation management
contractors. Please note that Zone II's and limited spray areas are not mapped since Eversource Energy,
will only use herbicides approved for use within this type of Sensitive Area in their 2023 IVM program.
There is one type of Sensitive Area not included on the maps that we are not authorized to
publish: the locations of the Priority Habitats of state listed species as regulated by the Natural Heritage
and Endangered Species Program (NHESP) of the Division of Fisheries & Wildlife. A map layer of
Priority Habitats is available to the general public at https://www.mass.gov/orgs/massgis-bureau-of-
geographic-information , but it is neither specific to areas of concern for herbicide applications nor does it
include data on the individual species since the exact location and details of their habitat is protected.
Please be assured that we follow all necessary precautions to stay in compliance with 321 CMR 10.00 and
this YOP was approved by NHESP.
Prior to any herbicide application, Sensitive Areas will be identified and when necessary marked
in the field by an experienced vegetation management treatment crew point person, by individuals trained
in the identification of Sensitive Areas that require the use of GIS (geographic information systems) and
GPS equipment, and/or by a NHESP approved botanist trained in the delineation of state-listed species.
Two simple descriptions guide the complex identification of the Sensitive Areas listed in 333
CMR 11.02: Readily identifiable in the field and Not readily identifiable in the field:
A. Readily identifiable in the field areas will be treated and marked according to all
applicable restrictions listed in 333 CMR 11.00 and the Eversource Energy,
5-year VMP’s.
B. Not readily identifiable in the field areas are identified by the use of the data marked on
our maps and additional data collected in the YOP and notification processes before the
time of treatment.
Eversource and contractor personnel assigned the task of identifying Sensitive Areas in the field
will use the following sources and methods:
A. Massachusetts Department of Environmental Protection (DEP) water supply maps/GIS
mapping layers available through Mass GIS
B. Massachusetts Department of Agricultural Resources (MDAR) records of identified
private wells along the ROW
6
C. Correspondence and input from municipalities within the consecutive forty-five day YOP
and twenty-one day municipal ROW notification review and comment periods and the 48
hour newspaper notification
D. Correspondence and input from Eversource’s abutter notification procedure
E. A point person who precedes the treatment crew verifying identified Sensitive Areas and
any additional areas that may require special precautions.
The following section details some of the Sensitive Areas that require special attention,
particularly those that are classified as either no spray or not readily identifiable in the field:
A. Limited Spray Areas:
Per 333 CMR 11.02, the following need to be identified in the field, require the use of herbicides
on the MDAR Rights-of-Way Sensitive Area Materials List, and time restrictions between
herbicide applications (see Appendix II, Sensitive Area Table). Please note that for 2023 IVM
herbicide applications, Eversource is only using Sensitive Area approved herbicides on our entire
ROW system:
(a) any Zone II or IWPA
(b) a distance of between 100 feet and 400 feet of any Class A Surface
Water Source
(c) a distance of between 10 and 200 feet of any tributary or associated
surface water body where the tributary or associated surface water
body runs outside the Zone A for the Class A surface water source
(d) a lateral distance of between 100 and 200 feet for 400 feet upstream,
on both sides of the river, of a Class B Drinking Water Intake
(e) a distance of between 50 and 100 feet of any identified Private Well
(f) a distance of between 10 and 100 feet of any Wetlands or Water Over
Wetlands
(g) a distance of between 10 feet from the mean annual high water line of
any river and the outer boundary of the Riverfront Area
(h) a distance of between ten feet from any Certified Vernal Pool and the
outer boundary of any Certified Vernal Pool Habitat
(i) a distance of 100 feet of any Agricultural or Inhabited Area.
Please Note that “(f)” is modified by the MDAR (formerly Department of Food and
Agriculture) Decision, dated October 12, 1995, concerning the wetland impact study conducted
pursuant to 333 CMR 11.04(4)(c)(2). According to the Decision, Eversource may use
herbicides within wetlands except on or within 10 feet of standing or flowing water (item “g” in
the no-spray areas below was removed from the no spray list for utilities because it does not
apply for the same reason).
B. No-Spray Areas:
Again, quoting from 333 CMR 11.02 the following no-spray areas need to be identified:
No-Spray Area, any area that is both within a Right-of-Way and within:
(a) any Zone I
(b) 100 feet of any Class A Surface Water Source
(c) 100 feet of any tributary or associated surface water body where the
7
tributary or associated surface water body runs within 400 feet of a
Class A surface water source
(d) 10 feet of any tributary or associated surface water body where the
tributary or associated surface water body is at a distance greater than
400 feet from a Class A surface water source
(e) a lateral distance of 100 feet for 400 feet upstream, on both sides of the
river, of a Class B Drinking Water Intake
(f) 50 feet of any identified Private Well [within 100 feet of the ROW]
…
(h) 10 feet of the mean annual high-water line of any river
(i) 10 feet of any Certified Vernal Pool.
C. Identification and Treatment of Private Drinking Water Supplies
No herbicide treatments will take place within fifty feet of any identified private wells
located within one hundred (100) feet of a ROW. Eversource updates its private well records
based on available data.
Municipalities should assist in the identification process and the MDAR will be consulted
again prior to the treatment in an attempt to keep the private drinking water supply information
up-to-date.
Identified private drinking supplies within one hundred (100) feet of a ROW will be
permanently recorded on appropriate maps.
D. State-Listed Species Habitat
Eversource recognizes the importance of the Massachusetts Endangered Species Act,
M.G.L.C. 131 A, and its significance to ROW vegetation management. Eversource will comply
with all applicable portions of this Act and the regulations promulgated thereunder. Eversource
will also follow the rules and prohibitions directed at human activities which Take Species or
alter their Significant Habitat (as of this printing there are no designated Significant Habitat in
Massachusetts).
321 CMR 10.14, Massachusetts Endangered Species Act Regulations, Part II Exemptions
and 333 CMR 11.04(3)(a-c) exempts utility ROW vegetation management from the permit process
under the following conditions:
(12) The management of vegetation within existing utility rights-of-way provided that the
management is carried out in accordance with a vegetation management plan approved in
writing by the Division prior to the commencement of work for which a review fee shall
be charged, the amount of which shall be determined by the commissioner of
administration under the provisions of M.G.L. c.7, § 3B…
To comply with exemption 10.14(12), Eversource submits this YOP to the NHESP for
review.
The NHESP has delineated areas as Priority Habitat based on the "Best Scientific Evidence
Available" to protect State-listed species from a "take." Under the approval process, details about
the Priority Habitat of state-listed species that might be affected by our activities and management
recommendations are shared with Eversource under strict confidentiality agreements. Using this
data and best management practices, Eversource and contract personnel will follow the
appropriate vegetation management treatment methods within these sensitive areas taking all
8
practical means and measures to modify ROW vegetation management procedures to avoid
damage to state-listed species and their habitat.
To identify Priority Habitats, Eversource personnel, NHESP approved review botanists
and vegetation management crews must use proper identification procedures. Contractors are,
therefore, required to train their personnel to recognize the location of Priority Habitats using one
of the following tools: paper maps, GPS coordinates and/or GIS systems.
VI. PROPOSED HERBICIDE TREATMENT METHODS
Under Eversource’s IVM program, combined with mechanical "prep-cutting," mowing and side-
trimming activities, herbicide applications will be applied on foot using selective low pressure foliage
treatments with backpack sprayers and cut stump or basal treatments. Experienced, Massachusetts
licensed applicators will perform the selective herbicide treatments under the direct on site supervision of
a certified applicator as required by Chapter 132B.
Eversource’s herbicide program is a selective program scheduled to sustain acceptable vegetation
control at minimal application rates. Using backpack sprayers, small amounts of herbicide are applied
directly to the leaves, stumps or bark of the target vegetation. The average per acre rate of herbicide mix
for Eversource’s foliar program is under 5 gallons per acre and the actual amount of applied active
ingredient is in the pints per acre range.
Eversource also chooses herbicide formulations that are low in acute toxicity, do not bio-
accumulate and, as applied, have a short half-life with low soil mobility (see VMP’s, Bibliography).
Above and beyond the review by the Federal EPA, these herbicides are all carefully reviewed jointly by
MDAR and the Massachusetts Department of Environmental Protect for use in “limited spray” sensitive
areas (including Zone IIs). Eversource takes this one step further and only uses sensitive area approved
herbicides on their entire right-of-way system.
A. Methods:
Eversource and contract personnel will utilize the most appropriate technique for the vegetation
species, height, density, site and mandated restrictions. These methods as described in detail in the
Eversource 5-year VMP’s are briefly reviewed below:
Low Volume Foliage Techniques utilize hand-operated pumps or motorized, backpack sprayers.
The motorized, backpack sprayer produces an air current that delivers small amounts of herbicide
mixture from a portable spray tank to the target vegetation. The low-pressure hand-pump sprayer
uses a column of water. In both cases, the amount of herbicide solution applied only dampens or
lightly wets the target vegetation.
Low-Volume Stem Basal: the selective application of herbicides to the lower 6"-8" of the plant
stem. The herbicide concentration is applied with low-pressure, backpack sprayers with special
wand attachments and positive shut-off nozzle tips with small orifices.
Cut Stump Surface Treatment (CST): the application of an herbicide mixture to the cut
surface of a stump immediately following or during a cutting operation. Application equipment
includes low-volume, backpack, hand-pump sprayers; hand held squirt bottles; paintbrushes, or
sponge applicators.
9
B. Guidelines:
1. All Sensitive Area restrictions will be followed.
2. Foliar and Basal treatments are used within the cleared width of the ROW for tree and shrub
target species below 12 feet in height.
3. CST treatments are used in conjunction with hand-cutting and in situations including but not
limited to: trees and shrubs that cannot be foliar treated, at road buffers, and around structures
such as poles and gates.
4. Only mechanical treatment methods will be used in no spray Sensitive Areas, including but not
limited to hand cutting, trimming and mowing.
C. Treatment of Wetlands
Herbicide applications in wetlands will be performed in accordance with 333 CMR 11.04
(4)(c)(2) relative to ROW management. Targets will be selectively treated with herbicides on the
MDAR’s Sensitive Area Material List and will not be applied within ten (10) feet of standing or flowing
water.
D. Treatment of State-Listed Priority Habitats
All vegetation management activities will be completed in compliance with the Massachusetts
Endangered Species Act (MESA; MGL c. 131 A) and its regulations, 321 CMR 10.00.
10
VII. PROPOSED HERBICIDES, CARRIERS, ADJUVANTS AND RATES
In 2023 only the Commonwealth of Massachusetts recommended herbicides listed below for use
in Sensitive Areas—pursuant to 333 CMR 11.04 (1)(d)—will be used on the entire length and cleared
width of Eversource Energy ROW corridors, in compliance with all labeled directions.
Table III. Tank Mixes for Low Volume Foliage Applications:
Tank Mix #1 for Low Volume Foliar (LVF) Treatment Applications
Tank Mix #2 for Low Volume Foliar (LVF) Treatment Applications
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration
(per 100 gals.
water)
Estimated
Application
Rate Per Acre
Krenite S Fosamine
Ammonium
42750-247 6-10% 32-128 oz.
Escort XP or Patriot Metsulfuron-
Methyl
432-1549 or 228-
391
2-4 oz. 0.125-0.8 oz.
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228-
534
0.125%-0.5% 2-8 oz.
Induce, Clean Cut,
Methylated Seed Oil
(MSO)3, or Aqua Fac or
equivalent surfactant2
n.a. n.a. 0.125%-1% 1-16 oz.
Point Blank, Clasp, or
equivalent drift retardant
n.a. n.a. 0.125%-0.5% 1-2 oz.
Carrier: Water n.a. n.a. n.a. n.a.
Gallons per acre – 3 to 15
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration
(per 100 gals.
water)
Estimated
Application
Rate Per Acre
Rodeo, Aquaneat, Roundup
Pro, or Roundup Custom4,5
Glyphosate 62719-324, 228-
365, 524-475,
524-343
3-5% 16-128 oz.
Escort XP or Patriot Metsulfuron-
Methyl
432-1549 or 228-
391
2-4 oz. 0.125-0.8 oz.
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228-
534
0.125%-0.5% 2-8 oz.
Induce, Clean Cut, MSO3, or
Aqua Fac or equivalent
surfactant2
n.a. n.a. 0.125%-1% 1-16 oz.
Point Blank, Clasp, or
equivalent drift retardant2
n.a. n.a. 0.125%-0.5% 1-2 oz.
Carrier: Water n.a. n.a. n.a. n.a.
Gallons per acre – 3 to 15
11
Tank Mix #3 for Low Volume Foliar (LVF) Treatment Applications
(can be used in MA only if MDAR approved Sensitive Materials List)
Tank Mix #4 for Low Volume Foliar (LVF) Treatment Applications
Tank Mix #5 for Low Volume Foliar (LVF) Treatment Applications
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration
(per 100 gals. water)
Estimated
Application Rate Per Acre
Escort XP or Patriot Metsulfuro
n- Methyl
432-1549 or 228-
391
2-4 oz. 0.125-0.8 oz.
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228- 534 0.125%-0.5% 2-8 oz.
Induce, Clean Cut, MSO3, or
Aqua Fac or equivalent
surfactant2
n.a. n.a. 0.125%-1% 1-16 oz.
Point Blank, Clasp, or
equivalent drift retardant2
n.a. n.a. 0.125%-0.5% 1-2 oz.
Carrier: Water n.a. n.a. n.a. n.a.
Gallons per acre – 3 to 15
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration
(per 100 gals.
water)
Estimated
Application
Rate Per Acre
Vastlan Triclopyr choline 62719-687 2-3% 12-64 oz.
Escort XP or Patriot Metsulfuron-
Methyl
432-1549 or 228-
391
2-4 oz. 0.125-0.8 oz.
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228-
534
0.125%-0.5% 2-8 oz.
Induce, Clean Cut, MSO3, or
Aqua Fac or equivalent
surfactant2
n.a. n.a. 0.125%-1% 1-16 oz.
Point Blank, Clasp or
equivalent drift retardant2
n.a. n.a. 0.125%-0.5% 1-2 oz.
Carrier: Water n.a. n.a. n.a. n.a.
Gallons per acre – 3 to 15
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration
(per 100 gals.
water)
Estimated
Application
Rate Per Acre
Escort XP or Patriot Metsulfuron-
Methyl
432-1549 or 228-
391
2-4 oz. 0.125-0.8 oz.
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228-
534
0.125%-0.5% 2-8 oz.
Induce, Clean Cut, MSO3, or
Aqua Fac or equivalent
surfactant2
n.a. n.a. 0.125%-1% 1-16 oz.
Point Blank, Clasp or
equivalent drift retardant2
n.a. n.a. 0.125%-0.5% 1-2 oz.
Carrier: Water n.a. n.a. n.a. n.a.
Gallons per acre – 3 to 15
12
Tank Mix # 6 for Low Volume Foliar (LVF) Treatment Applications
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration
(per 100 gals. water)
Estimated
Application Rate Per Acre
Garlon 4 Ultra Triclopyr 62719-527 2-4% 12-64oz
Escort XP or Patriot Metsulfuron- Methyl 432-1549 or 228- 391 2-4 oz. 0.125-0.8 oz.
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228- 534 0.125%-0.5% 2-8 oz.
Induce, Clean Cut, MSO3, or
Aqua Fac or equivalent surfactant2
n.a. n.a. 0.125%-1% 1-16 oz.
Point Blank, Clasp, or
equivalent drift retardant2
n.a. n.a. 0.125%-0.5% 1-2 oz.
Carrier: Water n.a. n.a. n.a. n.a.
Gallons per acre – 3 to 15
Table IV: Tank Mix for Poison Ivy, Vines, and Invasive Species
Table V. Tank Mixes for Cut Surface Treatment (CST) Applications:
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix Concentration (per
100 gals. water)
Rodeo, Aquaneat, Roundup Pro,
or Roundup Custom4,5
Glyphosate 62719-324, 228-
365, 524-475, 524-
343
2-5%
Garlon 4 Ultra Triclopyr 62719-527 2-4%
Escort XP or Patriot Metsulfuron-Methyl 432-1549 or 228-
391
1.25-4 oz.
Induce, Clean Cut, MSO3, or Aqua
Fac or equivalent surfactant2
n.a. n.a. 0.125%-1%
Point Blank, Clasp or equivalent
drift retardant2
n.a. n.a. 4-16 oz.
Carrier: Water n.a. n.a. n.a.
Gallons per acre – 3 to 15
Herbicides & Adjuvants Active Ingredient EPA
Registration
Number(s)
Mix Concentration
(per 100 gals.
water)
Estimated
Application Rate
Per Acre
Rodeo, Aquaneat, Roundup
Pro, or Roundup Custom4,5
Glyphosate 62719-324,
228-365, 524-
475, 524-343
40% to 50% Per density of
target stems
Arsenal Powerline or
Polaris1
Imazapyr 241-431 or 228-
534
3%-5% (mixed
with Glyphosate)
Per density of
target stems
Carrier: Water or
Windshield Washing Fluid
n.a. n.a. n.a. n.a.
13
Table VI. Tank Mixes for Low-Volume Basal or Cut Surface Treatment (CST)
Applications:
Tank Mix #1 Low Volume Basal or Cut Surface Treatments (CST) Applications
Tank Mix #2 Low Volume Basal or Cut Surface Treatments (CST) Applications
1 – Imazapyr will not be applied on the same right-of-way in two consecutive years
2 – Equivalent surfactants, drift retardants, and basal oils will be used if those listed are no longer available or more effective alternatives
become available
3 -Methylated Seed Oil (MSO) will be labeled for wetland uses
4- Roundup Custom ATU will only be used if added to the Massachusetts Sensitive Materials List
5- Additional Glyphosate products may be substituted depending on the availability of products or if additional products become available
VIII. ALTERNATIVE MECHANICAL CONTROL TECHNIQUES
Areas not treated or prohibited from herbicide use, such as protective buffers for Sensitive Areas,
will be maintained mechanically according to the specifications in the VMP’s. The following is a brief
review of these methods:
Hand Cutting: the use of chain and brush saws to remove the stem and/or branches from the
plant’s root system; can be combined with CST except in no-chemical restricted areas.
Mowing: the cutting, severing or shattering of vegetation by large rotary or flail mowers.
Side Pruning: side pruning or removal of encroaching tops and/or branches of trees growing on
or near the ROW's and access roads.
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix
Concentration
(per 100 gals.)
Estimated
Application Rate
Per Acre
Garlon 4 Ultra Triclopyr 62719-527 20%-30% Per density of
target stems
Polaris Imazapyr 228-534 3%-5% (mixed
with Garlon 4
Ultra)
Per density of
target stems
Carrier: Arborchem's low
odor basal oil or Aqumix
Plus basal oil with dye or
equivalent2
n.a. n.a. n.a. n.a.
Maximum of 8 gals. Per acre
Herbicides & Adjuvants Active Ingredient EPA Registration
Number(s)
Mix
Concentration
(per 100 gals.)
Estimated
Application Rate
Per Acre
Garlon 4 Ultra Triclopyr 62719-527 20%-30% Per density of
target stems
Carrier: Arborchem's low
odor basal oil or Aqumix
Plus basal oil with dye or
equivalent2
n.a. n.a. n.a. n.a.
Maximum of 8 gals. Per acre
14
IX. COMPANIES THAT MAY PERFORM THE HERBICIDE TREATMENT
Lewis Tree Service, Inc
300 Lucius Gordon Drive
West Henrietta, NY 14586
(585) 436-3208
X. INDIVIDUAL RESPONSIBLE FOR SUPERVISING THE OPERATION PLAN
William Hayes
Senior Supervisor
Eversource Energy
Transmission Vegetation Management
247 Station Drive, SW-1036
Westwood, MA 02090-9230
781-441-3932 (office)
XI. HERBICIDE FACT SHEETS
Herbicide Fact Sheets prepared and provided by the MDAR, explain technical information
relative to the herbicide concentrates proposed for use during the 2023 treatment cycle. These are
included in Appendix III, along with the manufacturer's labels in Appendix IV.
XII. PROCEDURES FOR HANDLING, MIXING AND LOADING HERBICIDE
CONCENTRATES
All herbicides will be handled, mixed and applied strictly according to Label Instructions and in
compliance with all applicable federal and state laws and regulations. If possible, herbicide mixing
should be done at the contractor's facilities and extreme care shall be exercised during all mixing,
handling and loading in order to prevent careless spills or splashes. No herbicide concentrates will be
mixed, handled or loaded on a ROW within one hundred (100) feet of a Sensitive Area.
XIII. EMERGENCY RESOURCES
Eversource contracts with independent, professional, certified herbicide applicators that are
responsible for the containment, clean up and reporting of chemical spills or accidents. The following is a
guide to the information sources that, according to various regulations, must be available to the treatment
crew in the event of a chemical spill or emergency situation:
A. Technical Reference Materials:
a. Product Label
b. Product Material Safety Data Sheet (SDS)
c. Product Fact Sheet, if available
15
B. Table VII. Herbicide Manufacturers:
MANUFACTURER TELEPHONE
NUMBER
SPECIAL INSTRUCTIONS
Albaugh Inc. 800-247-8013
BASF Corporation 800-832-4357
ENVU and Bayer Environmental
Science
800-334-7577
Corteva AgriScience 800-992-5994
Nufarm 877-325-1840 Medical Emergencies
C. Table VIII. State Agencies:
D. Table IX. Emergency Services:
EMERGENCY SERVICE TELEPHONE NUMBER SPECIAL INSTRUCTIONS
Massachusetts State Police,
Central Office
617-566-4500 or 911
Local Fire / Police Dept. 911
Chem Trec 800-424-9300
Clean Harbors 800-OIL-TANK
Pesticide Hotline 800-858-7378 PST: 8:00 am to 12:00 pm,
Web: www.NPIC.orst.edu
E. Eversource contact in the case of a spill or accident is:
System Control
Eversource
247 Station Drive
Westwood, MA 02090-9230
(617)-541-7858
STATE AGENCY TELEPHONE NUMBER SPECIAL INSTRUCTIONS
Massachusetts Pesticide
Bureau
(617) 626-1700 A.S.A.P. (within 48 hours)
Massachusetts Department
of Environmental
Protection, Emergency
Response Section
DEP 24 Hour
Contact:
(888) 304-1133
For emergencies involving
reportable quantities of
hazardous materials; required
info: City/town, street address,
site name (if applicable),
material
Southeast Region:
(508) 946-2700
Massachusetts Dept. of
Public Health, Bureau of
Env. Health Assessment
Toxicology Program
(617) 624-5757
Massachusetts Poison
Information Centers
(800) 682-9211 For medical emergencies
involving suspected or known
pesticide poisoning symptoms
16
F. Table X. Local Emergency Numbers:
Non-911 Emergencies Services for Eversource Electric Municipalities
Town Board of Health Town/City Hall Town Board of Health Town/City Hall
Bourne (508) 862-4644 (508) 862-4610