INTEGRATED_ VEGETATION_MANAGEMENT_PLAN by stariya

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									INTEGRATED VEGETATION MANAGEMENT PLAN

        TENNESSEE GAS PIPELINE
            RIGHTS-OF-WAY
                  in
             NEW JERSEY




           Tennessee Gas Pipeline
             El Paso Corporation
               8 Anngina Drive
          Enfield, Connecticut 06082




                February 2011
                                                TABLE OF CONTENTS
                                                                                                                                                Page

1. INTRODUCTION................................................................................................................................... 1
2. GOALS AND OBJECTIVES ................................................................................................................... 2
          GOALS .................................................................................................................................... 2
          OBJECTIVES ........................................................................................................................... 2
3. TARGET VEGETATION ....................................................................................................................... 3
          IDENTIFICATION OF TARGET VEGETATION ........................................................................ 3
          POISONOUS PLANTS .............................................................................................................. 3
4. INTEGRATED VEGETATION MANAGEMENT PROGRAM ................................................................. 4
5. DESCRIPTIONS OF INTENDED VEGETATION MANAGEMENT METHODS ........................................ 6
          SPECIAL FERC GUIDELINES ................................................................................................ 6
          CHEMICAL (HERBICIDE) CONTROL METHODS .................................................................. 6
          MECHANICAL METHODS .................................................................................................... 10
6. IDENTIFICATION OF SENSITIVE AREAS AND PROPOSED CONTROL STRATEGIES........................ 13
          IDENTIFICATION OF SENSITIVE AREAS ............................................................................. 13
          CHEMICAL CONTROL STRATEGIES FOR SENSITIVE AREAS ............................................ 14
7. OPERATIONAL GUIDELINES FOR APPLICATORS ........................................................................... 15
8. REMEDIAL PLAN TO ADDRESS SPILLS ........................................................................................... 17
          TYPES OF CHEMICAL SPILLS THAT REQUIRE ACTION .................................................... 17
          REQUIRED SPILL RESPONSE EQUIPMENT ......................................................................... 17
          INFORMATION SOURCES ..................................................................................................... 17
9. LANDOWNER NOTIFICATION PLAN ................................................................................................ 19
10. CUSTOMER SERVICE ........................................................................................................................ 21
          PROGRESS AND PERFORMANCE TRACKER/ISSUES LOG .................................................. 21
          CORE TEAM ......................................................................................................................... 21


                                                                   EXHIBITS
     1. FORM OF LANDOWNER NOTIFICATION LETTER
     2. FORM OF PRE-WORK “DOOR HANGER”
     3. FORM OF RIGHT-OF-WAY PROGRESS AND PERFORMANCE TRACKER


                                                               APPENDICES:
     1. DIVISION-SPECIFIC COMPONENTS

                 a. PERMITS

                 b. HERBICIDE LABELS AND ADDITIVES

                 c.    ALIGNMENT SHEETS
SECTION 1: INTRODUCTION

The pipeline companies comprising El Paso Corporation’s Eastern Pipeline Group have established a
nationwide Integrated Vegetation Management Plan (“IVM”) for use in conducting vegetation control
along rights-of-way occupied by their pipeline facilities. El Paso’s goal is to establish and maintain a gas
pipeline right-of-way that is reliable, accessible, and inspectable in support of El Paso’s mission: the
efficient, uninterrupted delivery of natural gas.

Tennessee Gas Pipeline (“TGP”) is one of the five interstate pipelines that make up El Paso’s Pipeline
Group. TGP is comprised of approximately 14,200 miles of pipeline that stretches from the Mexican
border to Canada including over 56 miles of high-pressure natural gas pipeline easements and associated
equipment in the State of New Jersey (see Figure 1). It maintains its pipeline in easements ranging from
50 feet in width on its laterals and up to 150 feet in areas of multiple pipelines (these pipeline rights-of-
way hereafter referred to as “ROW”s).

Pursuant to the federal Natural Gas Act, 15 U.S.C. §§ 717 et seq., the federal Natural Gas Pipeline Safety
Act, 49 U.S.C. §§ 60101 et seq., and the federal Hazardous Materials Transportation Act, 49 C.F.R., Part
192 (Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards), TGP is
required to adopt and implement an ongoing Operations and Maintenance Plan for purposes of
maintaining the integrity and safety of its pipeline facilities.

To facilitate compliance with 49 C.F.R., Part 192, Subpart L (Operations) and Subpart M (Maintenance),
TGP conducts periodic vegetation maintenance activities on its permanent easements. TGP must maintain
its easements: to allow for aerial and other types of surveillance of pipeline conditions, to enhance its
Damage Prevention Program, to facilitate planned cathodic protection surveys, and to allow access for
both routine pipeline maintenance and emergency repairs. Maintaining its ROWs free of encroaching
vegetation that may impede visual and physical access to the pipeline is critical to this surveillance.
TGP must also comply with all applicable federal regulations including, but not limited to: The
Endangered Species Act, The Migratory Bird Treaty Act, all applicable Federal Energy Regulatory
Commission (“FERC”) standards, Federal Occupational Safety and Health Act (“OSHA”) regulations,
and Environmental Protection Agency (“EPA”) regulations. In New Jersey, TGP must also comply with
New Jersey Pesticide Regulations NJAC Title 7 Chapter 30, New Jersey Freshwater Wetland Protection
Act Rules NJAC 7:7A, and Highlands Water Protection and Planning Act NJAC 7:38


Historically TGP has maintained its ROW in New Jersey by a 3 to 5 year mowing cycle, but now is
initiating an IVM program. The program should lessen equipment disturbance and habitat alteration,
increase efficiency, and increase the treatment cycle interval.




                                                  
SECTION 2: GOALS AND OBJECTIVES

As part of its ongoing commitment to public safety, TGP conducts a Right-of-Way Vegetation
Management Program that uses a variety of vegetation control methods, including tree cutting, mowing
and/or herbicide application.

GOALS

Goals of the Vegetation Management Program include the following.

   To establish a long-term, Integrated Vegetation Management (IVM) Program that takes advantage of
    technological advances and cost savings opportunities, all aimed at improving the effectiveness of
    TGP’s ROW maintenance processes. TGP intends to utilize herbicide application, where appropriate,
    as the predominant method of vegetation control in the future.

   To make the IVM Program environmentally responsible, legal, safe and flexible in order to
    accommodate unique situations and the need to use more appropriate techniques as they become
    known (in accordance with new regulations and/or scientific advances).

   To provide guidance for both TGP and contract personnel and to serve as a communication link for
    state and municipal officials, property owners, abutters and the public-at-large.

OBJECTIVES

Objectives of the Vegetation Management Program include the following.

   To maintain safe, reliable, functioning pipelines that comply with all applicable laws, rules and
    regulations.

   To control vegetation that impedes inspections or interferes with the ability to access the ROWs for
    maintenance or emergencies.

   To encourage stable early successional ecological communities of primarily lower growing grasses
    and forbs.

   To encourage the establishment of wildlife habitat that does not interfere with the primary function of
    the pipelines.

   To control invasive and poisonous plant species as required per employee concerns, construction
    permits, or in cooperation with regional invasive plant control strategies.

   To promote positive relationships with property owners, abutters, state and municipal officials,
    contractors, and the public.




                                                 
SECTION 3: TARGET VEGETATION

Most woody vegetation interferes with the safe, efficient and legal operation of a pipeline and restricts the
creation and maintenance of an easily recognizable ROW. According to Title 49, Part 195.146 of the
Federal Code of Regulations, TGP must regularly patrol its pipeline by ground and/or aerial inspections.
Tall, dense vegetation impedes the detection of leaks and other potential problems; the roots of large
woody plants interfere with pipeline anti-corrosion coatings; and woody vegetation obstructs the visibility
of and access to valve sites, pipe corrosion test stations, mile marker posts, and other pipe location
markers. The need to identify and reach these sites quickly is vital, especially during an emergency
situation. Therefore, TGP’s goal is to maintain a primarily early successional herbaceous vegetation
community across the width of its entire ROW, and where not possible due to permit restrictions, a
minimum ten-foot width of herbaceous vegetation centered over the pipeline.

IDENTIFICATION OF TARGET VEGETATION

Target vegetation will be identified and removed by professional, experienced, trained, licensed and
certified contractors. The primary target vegetation on TGP's ROWs includes, but is not limited to the
following.

           Trees, such as aspen, beech, birch, cherry, maples, oak and pines

           Shrubs, such as dogwood, high bush blueberry, buckthorn, honeysuckle, mountain laurel,
            speckled alder, sumac, willow, viburnum and witch hazel

           Woody vines and other vegetation, such as bittersweet, greenbrier, wild grapes, and
            blackberry

           Poisonous plant species, such as poison ivy and poison sumac.

Lower-growing woody vegetation, grasses, and herbaceous vegetation that compete with taller woody
vegetation generally do not interfere with the function and inspection of the pipeline, and create a
favorable habitat that is beneficial to both people and wildlife. These lower-growing species include, but
are not limited to: low-bush blueberry, huckleberry, sweet fern, grasses, ferns and wildflowers.


POISONOUS PLANTS

TGP personnel are required to maintain cathodic protection along the buried steel pipelines. Among other
duties, this entails regular maintenance of cathodic protection installations and appurtances, including
rectifiers, magnesium groundbeds and test stations. The plant communities around many of these
installations and appurtances are dominated by poison ivy, which is resulting in increased first aid cases
and OSHA reportable incidents.

Each identified hazardous location of poisonous plants requires applications of herbicides with backpack
or hand-held equipment along the ROW access path and up to 400 square feet surrounding the cathodic
protection device.

TGP's goal is to reduce poisonous plant species populations to a level that does not present a significant
injury risk to its personnel, while encouraging non-hazardous, native vegetation to become dominant.




                                                 
SECTION 4: INTEGRATED VEGETATION MANAGEMENT PROGRAM

This IVM Program takes into consideration various factors involved in the maintenance and operation of
pipeline ROWs. It reflects TGP’s intent to minimize adverse effects to the environment, while supporting
TGP’s primary obligation to deliver natural gas in a safe and dependable manner. The IVM Program is
summarized in Table 1 below.

                                                                             Table 1

                                                                   Integrated Vegetation Management
                                                            A combination of Mechanical, Chemical & Natural
                                                     vegetation management techniques that promote long-term control
                                                               with minimal impact on non-target organisms


                Mechanical Control                                          Chemical Control                                           Natural Control
  The physical removal of the stem and branch of                 The selective use of herbicides applied to          The science of working in concert with the stages of
 target vegetation by cutting, chopping or mowing,        the foliage, stems and/or root zone of target vegetation   plant succession and interspecies competition to limit
        usually leaving the root system intact                  to suppress growth and acheive root control             the establisment of taller undesirable vegetation


TGP’s experience is that sole reliance on cutting, mowing and other mechanical methods (e.g.,
excavation, hand-pulling) of vegetation control usually results in only temporary control, encourages
increased stem counts of woody vegetation, and may contribute to the spread of certain invasives,
especially those species capable of reproducing from rhizomes (creeping underground stems). Soil
disturbance associated with mechanical grading, excavation, or even mowing equipment can provide a
good opportunity for stem, root fragments, and seeds of invasives to advance into new sites. Additionally,
mowing produces an immediate loss of wildlife habitat due to its non-selective nature.

Mechanical vegetation management is currently performed on a 3 to 5 year cycle, but does not meet the
goal of maintaining a primarily herbaceous layer of vegetation directly over the pipeline. In certain areas,
more frequent mowing is required to control woody vegetation and promote a dominant herbaceous layer,
thus increasing potential impacts of erosion and compaction from heavy mowing equipment , and
potential accidental releases of hydrocarbons from hydraulic systems.

The selective use of herbicides is the tool of choice to control woody plant resprouts, invasives, and
poisonous plant species. There is little site disturbance associated with herbicide applications and the
entire target plant, including the roots, is controlled, stopping their spread by re-sprouts and rhizomes.
Selective application of herbicides to target species, as contrasted with mowing, does not produce an
immediate loss of wildlife habitat.

All poisonous plant species are best managed by early recognition and intervention before a small
intrusion becomes a large infestation. A quick response with appropriate control methods will reduce the
likelihood of a severe invasion. When aggressive invasive plant root systems are controlled, other
desirable native vegetation has an opportunity to reestablish dominance on the site, thus promoting
natural control.

Natural control is the process of working with the biological cycles of plant succession and interspecies
competition in order to lessen the dependence on chemical and mechanical controls. Since poisonous

                                                                            
plants are among the most aggressive vegetation species in the Northeast, herbicides are all the more
important as a control method. Selective herbicide applications will promote natural controls and reduce
the frequency and impact of treatment cycles, which will further reduce the potential negative impact
ROW maintenance, has on the environment from solely mechanical methods.

At the sites where TGP plans to utilize more than mechanical controls as the direct method of vegetation
management, herbicides will be used to encourage the development of natural controls and to reduce the
negative impact of mechanical controls. These herbicide treatment cycles will be scheduled to sustain
acceptable vegetation control at minimal application rates without jeopardizing pipeline operations.
Using historical mowing records for pipeline segments, TGP is scheduling initial herbicide applications to
begin the third growing season after mechanical mowing to provide the most effective treatment, with
followup treatments on a three year cycle or until vegetation control goals are reached, and a longer
interval is appropriate.

Herbicide applications minimize the personnel and equipment utilized, and their repeated impact on the
environment. They permanently control re-sprouts and increase the length of time between treatment
cycles by reducing the recurrence and density of target vegetation. Selective herbicide applications are
much less destructive than mowing to nesting habitat and the vegetative cover necessary for food and
concealment by wildlife.

The use of modern herbicide application equipment and restrictions to apply herbicides in the most
judicious manner practicable further minimizes environmental impacts. Herbicides, particularly when
applied selectively by low-volume methods, dry quickly on the plant surface, thereby significantly
minimizing the potential for dermal exposure. The use of anti-drift additives that can be adjusted to
accommodate changes in wind velocity in all foliage applications further limits the likelihood of
unintentional exposure to non-target organisms.

Applications will not be made in situations when there is a reasonable expectation that herbicides will
drift from the target, or during measurable precipitation. Herbicides will not be applied to target
vegetation standing in or near surface water, or in other circumstances that might materially jeopardize
the health and safety of humans, animals, or the environment. Restrictions on the use of herbicides near
sensitive areas are further detailed in Section 6.

Finally, professional, certified and licensed field personnel will carry out all vegetation management
activities in strict compliance with all applicable federal, state and local laws, rules, and regulations.




                                                   
SECTION 5: DESCRIPTIONS OF INTENDED VEGETATION MANAGEMENT METHODS

Details of TGP’s intended vegetation management methods are provided in the following text. The
methods include both chemical (herbicides) and mechanical techniques. Individual techniques described
include: foliar treatments, pre-emergent treatments, low volume basal treatments, cut stump treatments,
hand cutting, mowing, and selective trimming.

The treatment methods used on any given ROW are based on site sensitivity, regulatory mandates, target
species composition, density and height, site access, topography, and treatment methods. The goal is to
achieve a long term, low maintenance IVM program.

SPECIAL FERC GUIDELINES

Maintenance on pipeline ROWs under FERC certification are restricted by conditions of the certification.
FERC’s Wetland and Waterbody Construction Mitigation Procedures from certain original pipeline
certifications restrict mowing in sensitive areas, such as wetland and waterbody crossings. In New Jersey,
these FERC restrictions apply to the following pipelines: 300-2. In ROWs crossing wetlands for these
pipelines, TGP must restrict vegetation maintenance over the full width of the permanent ROW as
follows.

          A corridor centered on the pipeline and up to ten feet wide can be maintained in a herbaceous
           state.
          Trees within fifteen feet of the pipeline and greater than fifteen feet in height may be
           selectively cut.
          For waterbody crossings, TGP must limit vegetation management to allow a riparian strip at
           least twenty-five feet from the mean high water mark to revegetate with native plant species
           across the entire ROW.
        Additional FERC restrictions include the following.
          ROW access will be through the use of established roadways or access points whenever
           possible.
          Permission to enter a ROW by any other means must be obtained from the landowner.
          FERC Upland and Wetland Construction Mitigation Proceedures from certain original
           pipeline certifications restrict routine vegetation management between April 15th and August
           1st of each calendar year. The following Tennessee Gas Pipelines are not subject to the FERC
           restrictions except for Land Owner Notification: 300-1.
CHEMICAL (HERBICIDE) CONTROL METHODS

For purposes of this IVM, TGP contractors will utilize the following four chemical control treatment
methods.

           Foliar
           Pre-emergent
           Basal
           Cut and Stump Treatment

The applied mixtures will consist of herbicide(s), adjuvants, carriers and additives. The actual choice of
application methods depends upon many variables, including but not limited to: site sensitivity, regulatory
mandates, target species composition, density and height, topography, and access.


        The following general guidelines will be observed for all herbicide applications.


                                                
       Herbicide applications follow all restrictions in New Jersey Pesticide Regulations NJAC Title
        7 Chapter 30, New Jersey Freshwater Wetland Protection Act Rules NJAC 7:7A, and
        Highlands Water Protection and Planning Act NJAC 7:38.


       All herbicide applications will be performed by experienced, trained vegetation management
        personnel with current New Jersey Certified Pesticide Applicator Licenses and must be able
        to identify target and non-target species.

       The contractor is responsible for the proper disposal of all excess materials and solutions in
        accordance with all applicable Federal and State laws, regulations and guidelines.

       Mixing will take place according to all restrictions contained in NJAC Title 7 Chapter 30 and
        according to the chemical labels.

       Label restrictions for use of herbicides will be followed.

       Herbicide applications will follow the target vegetation and timing restrictions in the Pursuant
        to FERC Wetland and Waterbody Construction Mitigation Procedures, no applications
        within 100 feet of a wetland or surface water unless authorized by a permitting agency, or
        state regulation. The most restrictive requirements will be followed.

       Herbicides will not be applied to active pasture land unless arrangements are made with land
        owners to move livestock to an alternative location.

       Sensitive Area control strategies from Section 6, Table 1 will be followed at a minimum
        unless more restrictive requirements from pesticide label or permit apply.


    FOLIAR TREATMENTS:

Foliar application is the application of herbicides to fully developed leaves, stems, needles or blades
of a plant. The herbicide concentrate is usually mixed or diluted with water and applied as a uniform
spray over the plant’s foliage. Two types of equipment for foliar treatments are used: back pack and
vehicle mounted. Both treatments use low pressure, below 60 pounds per square inch (psi) at the
nozzle, for applications. The application period usually extends from early June through the
beginning of leaf abscission in early fall when not restricted by regulations. This is generally the
most economical and effective method, particularly in medium and high brush density situations. It is
also the best technique to control noxious and poisonous vegetation that presents a hazard to
inspection and maintenance crews.

    Low Volume Backpack Foliar Techniques utilize hand-operated pumps or motorized, backpack
    sprayers. The motorized, backpack sprayer produces an air current that delivers the herbicide
    mixture in small droplets from the portable three to five gallon spray tank to the target vegetation.
    Both techniques only require the applicator to dampen or lightly wet the target leaf area not to the
    point of runoff. This minimizes the amount of excess herbicide drip from target species onto
    desirable ground cover. Low volume applications also eliminate the need to bring heavy
    equipment on the ROW for the transportation of large quantities of herbicide solution. In
    regulated wetland areas, aquatic approved herbicides will be used (See Section 6, Table 1).

    Low Volume Hydraulic Foliar Techniques generally utilize a 100-500 gallon hydraulic sprayer
    mounted on a truck, tractor or tracked vehicle equipped with hand-held spray guns. The

                                             
        herbicide mixture is directed at specific vegetation or broadcast for uniform coverage. Specially
        designed showerhead-type nozzles reduce spray volumes and limit droplet fines thus reducing the
        potential for spray drift off-target. These nozzles deliver effective spray coverage at relatively
        low spray pressures of 60 psi and less. This technique is capable of delivering uniform,
        penetrating spray coverage to dense, tall, target vegetation. It is particularly useful for sites where
        total vegetation control or pre-emergent herbicide applications are required for fire safety, such as
        at compressor stations and valve sites or for initial treatment of invasive plants. In regulated
        wetland areas, aquatic approved herbicides will be used (See Section 6, Table 1).

        The following guidelines are observed in all foliar applications.

            1. Anti-drift Agents are added to the mix or solution in all foliage applications to reduce the
               potential of herbicide drift beyond target vegetation. Drift control agents reduce the
               break-up of sprays into fine droplets and offer increased selectivity, leaf tissue
               penetration, and herbicide deposition on target plants.

            2. Foliar applications are not used in the following situations.

                        Target vegetation is over twelve feet in height.
                        Target vegetation is in surface water.
                        During periods of wind, which are strong enough to bend the tops of the main
                         stems of tree species on the ROW.
                        During periods of moderate or heavy rain fall (where leaf runoff can wash the
                         herbicide off the target plants).
                        Where landowner agreements preclude their use.

             Foliar treatments are effective in light mist conditions.

             Foliar treatments are an effective method to convert ROWs previously maintained by
               mechanical only methods by treating resprouts after a preparatory mowing operation.


        PRE-EMERGENT TREATMENTS:

Pre-emergent treatments involve the use of non-selective pre-emergent herbicides that prevent seeds from
sprouting using the same equipment and guidelines described in the foliar treatments above. Pre-
emergent applications are used where season long vegetation control requires “vegetation-free
conditions,” such as around valve sites, meter station, compressor stations, and cathodic protection
installations. By preventing the growth of vegetation, pre-emergent applications reduce the amount of
applied herbicides and the number of applications necessary in a season. This method is used from the
early spring to early fall. See Section 6, Table 1 for restrictions in sensitive areas.




                                                  
        CUT AND STUMP TREATMENTS (CST):

Cut and stump treatment involves the application of an herbicide mixture diluted in water or a non-
freezing agent to the cut surface of a stump immediately following or during a cutting operation to
prevent resprouts and root suckering. To obtain root control, it is only necessary to treat the phloem and
cambium tissue, regardless of the stump diameter. Treatment should, however, ideally be made to freshly
cut stumps. Application equipment includes low-volume, backpack, hand-pump sprayers; hand held
squirt bottles; paintbrushes, or sponge applicators. In regulated wetland areas, aquatic approved
herbicides will be used (See Section 6, Table 1.)

        The following guidelines are observed in all CST applications.

             CST is used for the following reasons/situations.

                       To reduce the need to re-treat the same vegetation by controlling the root system.
                       To reduce the visual impact of vegetation management treatments.
                       For its selectivity to protect desirable vegetation.
                       At any time of the year.
                       To prevent resprouts of vegetation over twelve feet in height cut in preparation
                        for a foliar application.
                       To chemically treat target vegetation in sensitive areas where other methods are
                        not possible.

             CST is best avoided under the following conditions.

                       During the season of high sap flow.
                       In moderate to heavy stem densities.

             CST is not used under the following conditions.

                       In moderate to heavy rains.
                       In deep snow that prevents hand cutting (see Hand Cutting below).
                       In chemical restricted sensitive areas.

        LOW VOLUME BASAL TREATMENT:

Low volume basal is the selective application of an herbicide, diluted in specially formulated oil, to wet
the entire lower twelve to eighteen inches of the main stem of target plants. Using a hand pump backpack
unit, the oil enables the herbicide solution to penetrate the bark tissue and translocate within the plant.

        The following guidelines are observed in all Low Volume Basal applications.

             Low volume basal treatments are extremely selective and used under the following
               conditions.

                       When vegetation density is low.
                       In areas where extreme selectivity is necessary.
                       Any time of year, including in the dormant season when foliage, grasses and
                        herbaceous plant are not obstructing the main stem.




                                                
             Low volume basal treatments are not used under the following conditions.

                       In moderate to heavy rains.
                       In deep snow that prevents treating the lower twelve to eighteen inches of the
                        main stem of target plants.
                       In chemical restricted sensitive areas.
                       During spring sap flow.

MECHANICAL METHODS
Mechanical control methods include hand cutting, mowing, and side trimming. General and specific
guidelines for the use of mechanical methods are provided in the following text.

        The following guidelines are observed in all mechanical operations.

        1. As much as possible, mowing and side trimming takes place in the late summer, fall or winter
           months to minimize ground disturbance.

        2. Areas too saturated to support mowing equipment are hand-cut.

        3. TGP's mowing contractors are expected to repair any rutting and utilize existing permanent
           stream crossings whenever possible.

        4. All mechanical equipment is expected to be in sound operating condition.

        5. Treatment crews will have petroleum spill kits available on site in the event of an incident.

        6. Mechanical controls are used when conifers exceed six inches in height or are present in
           wetlands.

        7. Mechanical controls are used in easement restricted areas and where landowner agreements
           preclude herbicide use.


        HAND CUTTING:

Hand cutting involves the use of chain saws and brush saws to cut the stem and/or branches of plants.
Hand cutting is used to remove hazard trees, remove target vegetation greater than twelve feet tall, to
protect environmentally sensitive sites, and where herbicide use is prohibited. Hand cutting is also used
on sites where terrain, target species size, or sensitivity renders mowing impossible or impractical. Hand
cutting may be used at any time of the year.

        The following guidelines are observed during hand cutting operations.

        1. Target plants are cut as close to the ground as practical with stump height usually no higher
           than root swell.

        2. All mechanical method targeted plants greater than six inches in diameter at breast height
           (DBH) shall be hand cut.




                                                
        3. Cut stems/slash are piled and/or diced as follows.

                   In areas of medium to heavy density target plants, slash is either left parallel to the
                    ROW or in wind rows no greater than three feet in height along the edge of the ROW
                    corridor.
                   In areas of very light to light density target plants under six inches DBH, slash is
                    diced where it falls so that it lies as close to the ground as practical; the diced slash
                    should not exceed two feet in height.
                   Larger trees are limbed and diced.
                   A twenty-foot-long fire break is maintained for every 100’ of wind row.
                   Slash will not be left in or on waterways, fence lines, stone walls, trails or roads, or in
                    a manner that would permit it to wash into these areas.
                   Slash from yards or recreational sites will be chipped or removed to adjacent areas
                    for disposal.

        4. The placement of cut brush/slash must comply with applicable state and local Fire Marshall’s
           regulations.

        5. All cut cherry is removed from active pastures.

        6. Chipping is used at sites when dicing or piling are prohibited, impractical, or near residences.

        7. Wood chips will be removed, or scattered uniformly over the site at depths not exceeding
           four inches.

        8. Where applicable, FERC Wetland and Waterbody Construction Mitigation Procedures
           restrict hand cutting in areas, such as wetland and waterbody crossings, as follows.

                   Within the twenty-five foot wide riparian strip at waterbody crossings (from the
                    mean high water mark), all woody vegetation may only be removed in a 10-foot wide
                    corridor centered on the pipeline.
                   Trees within fifteen feet of the pipeline and greater than fifteen feet in height may be
                    selectively cut.

        MOWING:

Mowing is the cutting, severing or shattering of vegetation by large rotary or flail mowers. Heavy-duty
mowers, usually ranging from five to eight feet wide, are typically mounted on large four-wheel drive
rubber tired tractors or tracked vehicles; these vehicles may weigh several tons each. Mowing may be
used at any time of the year except when snow precludes operations.

        The following guidelines are observed during mowing operations.

        1. Mowing height is no higher than six inches unless required by regulation.

        2. Operators must perform daily integrity inspections of hydraulic systems and carry petroleum
           spill control equipment on the mowing machines.

        3. Operators must use designated access to ROW.

        4. Mobile equipment shall not intrude into residential lawn areas.

                                                
        5. Operators must permanently repair rutting and scarification of the ROW.

        6. Mowing is used on sites under the following conditions.

                   Where herbicide use is prohibited by regulatory or easement restriction(s).
                   Where a large number of target plant stems have exceeded maximum control density
                    and hand cutting is inefficient and expensive.
                   Where access is required in the short term in areas impeded by high woody
                    vegetation density.
                   Where terrain, site size and sensitivity permit the efficient use of the equipment.

         To reduce the impact to non-target organisms including food, cover and nesting sites for
           migratory wildlife, TGP schedules routine mowing activities after the primary nesting season
           (generally from mid-April to mid-July) except during emergencies or under extenuating
           circumstances.

         All mechanical method target species greater than six inches DBH shall be handcut not
           mowed.

         Hand cutting will be used in areas where mowing is restricted by terrain conditions such as
           steep, rocky sites, wet soils, residential lawn areas, or next to obstructions such as stone walls
           and fence lines.

         FERC Wetland and Waterbody Mitigation Procedures from certain original pipeline
            certifications may also restrict mowing in sensitive areas, such as wetland and waterbody
            crossings, as described in the following.

                   Within the 25-foot wide riparian strip at waterbody crossings (from the mean high
                    water mark), all woody vegetation may only be mowed in a 10-foot wide strip
                    centered on the pipeline.
                   No mowing within wetlands except for a 10-foot wide strip centered over the
                    pipeline.

         Care must be exercised to insure the safety of the general public as mowing brush can throw
            large chips and debris great distances from the cutting equipment, and, when appropriate,
            requires employing someone to prevent people and animals from coming too close to the
            work site.

        SIDE TRIMMING:

Side trimming is the cutting or removal of encroaching tops and/or branches of trees growing on or near
the ROW in such a manner that they cause a hazard, hamper access, and/or impede visual inspections.
This management technique is usually accomplished by the use of an aerial lift mounted on a street or off-
road vehicle, although, tree climbing is sometimes employed in situations where terrain prevents the
passage of equipment. This method is useful in maintaining the edge definition of the ROW corridors,
and provides for easier inspections of vegetation conditions during aerial patrols. All trimming activities
are performed in accordance with proper arboriculture practices and in compliance with all applicable
regulations in order to insure the health and aesthetic value of the trees.




                                                
SECTION 6: IDENTIFICATION OF SENSITIVE AREAS AND PROPOSED CONTROL STRATEGIES

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 areas: water supplies, surface waters including wetlands,
cultural sites, and wildlife areas. Identified sensitive areas are listed in Division-specific IVM Plans,
which include marked up pipeline alignment sheets, permits, and GIS mapping. This information is
communicated to the vegetation management contractor prior to work on the pipeline ROW or facilities.

IDENTIFICATION OF SENSITIVE AREAS
Sensitive areas can be divided into two categories that help the individuals assigned the task of identifying
and treating them in the field; the categories are: “readily identifiable in the field” and “not readily
identifiable in the field.” Readily identifiable in the field areas will be treated, identified and when
appropriate, marked according to all applicable restrictions. Areas not readily identifiable in the field will
likewise be treated and marked when appropriate, but they are identified by the use of data marked on
maps and collected in the permitting 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, and inhabited and agricultural areas. It should be noted that
registered organic farms are not easily identifiable in the field, but they are identified in TGP’s abutter
notification process.

Sensitive areas not usually identifiable in the field, include, but are not limited to: designated public
surface water supplies, public ground water supplies, some private drinking supplies, and habitat of state-
listed species.

As appropriate, therefore, sensitive areas will be identified and marked in the field by either TGP
personnel, trained and experienced vegetation management contractor personnel, and/or by individuals
trained in the identification of sensitive areas.

The following resources help in the identification of sensitive areas.

    1. TGP’s pipeline alignment sheets, maps, records and institutional knowledge.

    2. TGP permitting documents, including original construction permits.

    3. GIS mapping layers and aerial photographs available through New Jersey GIS, and others.

    4. Board of Health maps and lists of identified private wells.

    5. Consultations with U.S. Fish &Wildlife Service and NJDEP Endangered Species Program.

    6. Correspondence and meetings resulting from TGP's abutter notification procedure.

    7. A point person who verifies identified sensitive areas and any additional areas that may require
       special precautions.

    8. USGS topographical maps.

    9. Information from contractor’s knowledge and records.
    10. Treatment crews are required to have the following references on the job site to help identify
        sensitive areas.

                                                 
                     Topographical maps (electronic or paper)
                     Copy of permits
                     Pipeline alignment sheets
                     Any additional information that may become available.

CHEMICAL CONTROL STRATEGIES FOR SENSITIVE AREAS

Identified sensitive areas are listed in Division-specific IVM Plans, which include marked up pipeline
alignment sheets, permits, and GIS mapping data. This information is communicated to the vegetation
management contractor prior to work.

A key strategy to minimize off-target damages to sensitive areas is to designate buffer zones around these
areas. The following Table 1 lists the minimum buffer zones around sensitive areas; these zones may be
increased per permit or label restrictions.

                     TABLE 1 – CHEMICAL CONTROL STRATEGIES FOR SENSITIVE AREAS

     SENSITIVE AREA                      MINIMUM BUFFER ZONE                 CONTROL METHOD
     Public Ground Water Supply
                                         400 feet                            No chemical allowed
     well
     Public Surface Water Supplies       100 feet                            No chemical allowed
     Private Drinking Water Supply
                                         100 feet                            No chemical allowed
     well
                                         25 feet (LV Hydraulic)
     Surface Waters*                     10 feet (LV Backpack)               No chemical allowed
                                         5 feet (CST)
                                                                             Low-volume backpack foliar,
                                         Surface water buffers apply
                                                                             CST,Vehicle mounted LV
                                         where water present. Treatment
     Wetlands*                                                               hydraulic
                                         in wetlands per approved
                                                                             Recommended aquatic
                                         wetland permit.
                                                                             herbicides
                                         100 feet (LV Hydraulic, LV           CST
     Habitated Areas
                                         Backpack, LV basal)
                                                                             CST
                                         50 feet (LV Hydraulic, LV
     Agricultural Areas                                                      Recommended aquatic
                                         Backpack, LV basal)
                                                                             herbicides
     Endangered and Threatened           Per specific agency                 Per specific agency
     Species                             recommendations or permit           recommendations or permit
    *FERC restrictions require minimum 100 feet buffer and no chemicals allowed without permit.

Reference sources: Treatment crews are required to have the following references on the job site to help
identify sensitive areas.

                     Copy of division-specific IVM Plan
                     Maps provided by the contractor
                     Permits
                     Pipeline alignment sheets
                     Any additional information that may become available




                                                 
SECTION 7: OPERATIONAL GUIDELINES FOR APPLICATORS

TGP’s contract with its independent contractors for vegetation management requires that contractors
comply with all applicable federal and state laws and regulations. This includes, but is not limited to,
applicable OSHA and DOT regulations. General operational guidelines are as follows.

    1. Both the contractor and TGP are responsible for conducting vegetation management activities in
       a professional, safe, efficient manner, with special attention paid toward minimizing
       environmental impacts.

    2. The contractor must provide qualified, state licensed and certified personnel to apply herbicides
       to TGP’s ROW. “Qualified” mean personnel who have been trained to recognize and identify
       target and non-target vegetation and to be knowledgeable in the safe and proper use of both
       mechanical and chemical vegetation management techniques.

    3. Vegetation management crews will exercise care to prevent non-target organisms from being
       unreasonably affected by the application of herbicides.

    4. Herbicides are only applied in a safe and judicious manner, in compliance with applicable state
       and federal pesticide regulations.

    5. Herbicides are to be handled and applied only in accordance with the label instructions.
       Contractors will strictly adhere to all mandated safety precautions directed toward the public, the
       applicator, and the environment. While performing treatment on TGP’s ROWs, herbicide
       applicators will wear any and all personal protection equipment enumerated on product labels.

    6. Applicators will at all times exercise good judgment and common sense during herbicide
       treatment activities, and will immediately cease the operation if adverse conditions or other
       circumstances warrant.

    7. Herbicides are not applied during the following adverse weather conditions.

                   During high wind velocity.
                   Foliar applications during periods of dense fog, or moderate to heavy rainfall.
                   Foliar applications of volatile herbicides during periods of high temperatures (90 plus
                    degrees Fahrenheit), and low humidity.
                   When deep snow (i.e. 6” plus or ice frozen on stem or stump) prevents adequate
                    coverage of target plants to facilitate acceptable control.

    8. The contractors’ foreman or senior member of the crew must complete daily vegetation
       management reports. These forms will be submitted to TGP and require the following
       information.

                   Date, name and address of vegetation management contractors.
                   Identification of site or work area.
                   List of crew members.
                   Type of equipment and hours used, both mechanical and chemical.
                   Method of application.
                   Target vegetation.
                   Amount, concentration, product name of herbicide(s), additives, diluents, and EPA
                    registration numbers.
                   Weather conditions.
                   Notation of any unusual conditions or incidents, including inquiries from the public.

                                                
9. All equipment used for vegetation management programs must be maintained in good working
   condition, and shall be of adequate design and functional ability to produce the professional
   quality of work that TGP requires.

10. All vehicles shall be equipped with absorbent material or pads in the event of a spill.

11. The vegetation management program must result in a 95% control of all target species. If less
    than the desired control is achieved, the contractor may be held responsible to re-treat or remove
    the remaining vegetation to TGP’s satisfaction.

12. The owner(s) of the land, will at all times be treated with courtesy and respect. Permission must
    be obtained if entering the ROW from private land, and precaution and common sense shall be
    exercised when moving vehicles and equipment. All bar-ways and gates shall be immediately
    closed, and care must be exercised to prevent the rutting or destruction of roadways or any other
    form of access. The treatment crew will not leave litter of any kind on the ROW or adjoining
    land.

13. When addressing inquiries or complaints from a landowner or other concerned person, the
    foreman of the ROW crew will explain the program in a polite and professional manner. If there
    is a demand from the landowner that the vegetation maintenance cease, then the foreman should
    remove the crew and equipment off the property, and the TGP representative should be contacted
    as soon as possible and advised of the situation. The crew will not return to that location until
    given clearance by TGP.




                                            
SECTION 8: REMEDIAL PLAN TO ADDRESS SPILLS

TGP’s contractors are responsible for all aspects of ROW applications, including containment, cleanup
and reporting of chemical spills or accidents. Contractors are expected to immediately contact TGP upon
discovery of a release of chemicals to the environment. TGP expects that all contractors will comply with
the following minimum standards, while maintaining their own expertise in this area.

TYPES OF CHEMICAL SPILLS THAT REQUIRE ACTION

Any chemical outside of its proper container or intended use can be considered a spill. Chemicals include,
but are not limited to, the following items.

                     Herbicides
                     Bar and Chain Oil
                     Motor & Hydraulic Oil
                     Diesel Fuel
                     Gasoline

REQUIRED SPILL RESPONSE EQUIPMENT

Spill response equipment is required on the job site. As a minimum, the treatment crew should have the
following items available on the job site.

                     Product Material Safety Data Sheets (MSDS) and product labels
                     Appropriate absorbent material such as “speedi dri” or “soak up”
                     Shovel
                     Broom
                     Flagging
                     Leak proof container
                     Heavy-duty plastic bags

INFORMATION SOURCES

Product information sources and emergency contacts shall be available. These sources include the
following.

    Technical Reference Materials:

               Product Label
               Product Material Safety Data Sheet (MSDS)
               Product Fact Sheet, if available

    Manufacturers:

            MANUFACTURER              TELEPHONE NUMBER          SPECIAL INSTRUCTIONS
            BASF Corporation          (800) 424-9300 Chemtrec   in case of emergency
            DOW                       (800) 424-9300 Chemtrec   in case of emergency
            Nufarm                    (800) 424-9300 Chemtrec   in case of emergency

    State Agencies:

            STATE AGENCY              TELEPHONE NUMBER          SPECIAL INSTRUCTIONS
            NJDEP                     (877) 927-6337


                                                 
Emergency Services:
        EMERGENCY SERVICE   TELEPHONE NUMBER
        Clean Harbors       1-800-645-8265




                              
SECTION 9: LANDOWNER NOTIFICATION PLAN

Affected landowners will be notified via mass mailing prior to commencing herbicide application. The
mass mailing address list will be generated by DOT Compliance Services – based on a 600 ft. corridor
(300 ft. on either side of the pipeline). The form of Landowner Notification Letter is attached hereto as
Exhibit 1.

Landowners will be asked to review the letter and an attached information sheet carefully and contact
TGP via toll-free number or email within 15 days of receipt should they have concerns or objections. A
contract answering service will receive all initial calls from landowners responding to the letter and shall
follow the steps outlined below.

           Collect from caller

                Name

                Address

                County

                Phone

                Email

                Best time to call

                Description of concerns

           Compile information

                Excel spreadsheet

           Convey to landowner

                Email to Property Rights

Property Rights (Houston) will receive concerned landowner information (Excel spreadsheet) from
answering service and post it to a master tracking log. Property Rights (Houston) will distribute the
information to the appropriate Field Property Rights Specialist for handling.

Field Property Rights Specialists will coordinate landowner response activities and conduct proper
follow-up using the resources/steps outlined below.

                            Resources

                                       Field Property Rights Specialists (primary caller)

                                       Core Team members (if requested by Field Property Rights)

                                       Local operations supervision (if requested by Field Property Rights)




                                                   
                            Approach

                                    Answer questions/educate

                                    Obtain permission or refusal

                            Communication Methods

                                    Phone call

                                    Face-to-face (as needed)

                            Documentation

                                    Master log will be updated to reflect all results of landowner
                                     contacts:

                                         o   Field Property Rights Specialist, or

                                         o   Property Rights in Houston, or

                                         o   Core Team (as appropriate)

           Pre-work review of Master Tracking Log (Property Rights and Core Team) to address
            unresolved issues as follows.

                            Landowners who have not been reached (blanks in the log)

                            Landowners who have been contacted but additional follow-up is needed

                            Landowners who have denied permission to use herbicides

           Core Team and Field Property Rights Specialist identifies “no herbicide use” areas

                o   Core Team communicates “no-herbicide use” areas to Area Operations Manager and
                    contractor prior to and during pre-job meetings

           Annual Review Landowner Notification Process – Property Rights and Core Team

Prior to the spraying operations, the Contractor will distribute “door hangers” on all residents within the
600 ft.-wide corridor informing the residents of the upcoming work. The form of the pre-work door
hanger is attached hereto as Exhibit 2, which will be revised as needed to be pipeline subsidiary-specific
(Tennessee Gas Pipeline, Southern Natural Gas Company, etc.)




                                                  
SECTION 10: CUSTOMER SERVICE

PROGRESS AND PERFORMANCE TRACKER/ISSUES LOG

Once spraying operations commence, Core Team members will field calls from Operations supervision or
landowners in their respective divisions and log information on a SharePoint-housed tracking spreadsheet.
Contractor’s Project Manager will have ready access to the online tracker and will be notified
immediately for all items requiring a response from the contractor. Target response time for follow-up
calls is 24 hours.

Core Team (division-specific) will notify Field Property Rights Specialist about any calls pertaining to
landowner issues. Contractor’s Project Manager has ultimate responsibility for responding to all calls
from landowners and Operations supervision.

Core Team will review the tracker monthly and liaison with the Contractor’s Project Manager to ensure
all landowner and contract performance issues are being addressed, resolved and documented in a timely
manner.

CORE TEAM

TGP intends to utilize the Core Team to manage the IVM Program and related processes on an ongoing
basis.




                                                
                   EXHIBIT 1 – FORM OF LANDOWNER NOTIFICATION LETTER


{ Insert Date}

Dear Pipeline Neighbor,

Did you know that vegetation on a pipeline right-of-way has the potential to increase the likelihood of
damage to critical natural gas transportation facilities? As part of our ongoing commitment to public
safety and to our vision of being the Neighbor to Have across our operations, { Insert Name of Pipeline
Subsidiary} ({ Insert Pipeline Subsidiary Contraction, e.g., “TGP”, “SNG”…} ) uses a variety of
vegetation control methods, including tree cutting, mowing and the application of herbicides as part of
our comprehensive right-of-way management program. We’re writing today to tell you about the program
and ask for your help.

Our program has three key objectives:

       Prevention. Keeping our right-of-way clear of large vegetation alerts contractors and others to the
        presence of the underground pipeline and related facilities, helping reduce the likelihood
        of third party damage to facilities.

       Response. A clear right-of-way will help workers and equipment respond quickly in the unlikely
        event of an emergency.

       Monitoring. A clear and open right-of-way allows us to frequently inspect our pipelines by
        patrolling them from the ground or air. These patrols help us meet our strict standards for public
        safety as well as requirements by the U.S. Department of Transportation, Pipeline Hazardous
        Materials Safety Administration.

We wanted you to know that beginning on or after { Insert Date} , we’ll be conducting right-of-way
maintenance activities in your area that will involve the careful application of herbicides to targeted plant
species on the right-of-way. Here’s what you can expect. In most instances, our contractors use low-
volume, backpack-type sprayers to target undesirable woody plant species and tall weeds to help keep our
right-of-way clear.

This process has several advantages. First, it ultimately promotes a healthy, meadow-like habitat for
desirable, native plant and wildlife species. Additionally, compared to traditional methods of right-of-way
maintenance such as mowing and brush-hogging, this method reduces the spread of undesirable plant
species, minimizes damage to ground-nesting animals. Finally, this method also helps reduce rutting on
the surface of the right-of-way, minimizes emissions and noise from mowing equipment, and reduces the
frequency of right-of-way maintenance activities that could impact your property in the future.

Herbicides have been applied to control vegetation on rights-of-way in an environmentally sound manner
for many years. Our contractors use only herbicides that have been approved by the Environmental

                                                 
Protection Agency and { Insert State} for use in sensitive areas will be used, and may include: { Insert
Name of Herbicides} . Our contractor will use these herbicides in accordance with all applicable federal,
state, and local laws, rules, and regulations. To learn more, please refer to the attached flyer for additional
information.

What do you need to do? If you’d prefer we not use herbicides on your property, please contact { Insert
Contact Name} at { Insert Contact’s Telephone Number} or please send an e-mail to { Insert
Contact’s e-mail Address} . If we don’t hear from you within 15 days of the date of this letter, we’ll
assume you authorize { Insert Pipeline Subsidiary Contraction} to proceed with the herbicide control
of vegetation on our pipeline right of way.

Finally, if you’re not the owner of this property, please help us ensure the proper owner is notified by
either informing the landowner about this letter or calling the number shown above and providing the
owner’s contact information so that we may do so.

{ Insert Pipeline Subsidiary Contraction} is committed to your safety and to being the Neighbor to
Have in communities across our pipeline system where we operate. Working together, we can keep our
pipeline safe and help protect your property.

Sincerely,

{ Insert Contact Name}
{ Insert Contact Title}

Enclosure: Herbicide Information Sheet

Note: For the purpose of this communication, the term “right-of-way” includes any land area for which {
Insert Pipeline Subsidiary Contraction} possesses land rights, whether the rights were conveyed by a
right-of-way easement, lease, or other land rights document. Also, this letter does not in any way amend
or release any of { Insert Pipeline Subsidiary Contraction} ’s land rights on the property. In situations
where a right-of-way agreement or other land rights document contains express authorization for
herbicide use, that document will control and { Insert Pipeline Subsidiary Contraction} will proceed in
accordance with the document’s provisions.




                                                  
EXHIBIT 2 – FORM OF PRE-WORK DOOR HANGER
            (Pipeline Subsidiary-Specific)




                

                               APPENDICES



I.   NORTHERN DIVISION – NEW JERSEY

       a. Permits

       b. Herbicide Labels

       c.   Alignment sheets




                                

								
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