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Permit L08-018 - BURNETT CATE - PSE SPECIAL PERMISSION
PSE 2008 MAINTENANCE SPECIAL PERMISSION L08-018 • MEMORANDUM DATE: March 31, 2009 TO: Laurie Anderson, Fiscal Specialist FROM: Jaimie Reavis, Assistant Planner RE: Refund for concurrency fees paid under permit number L07 -026 In May 2008, Puget Sound Energy (PSE) applied for a SEPA/Environmental Review permit (E08 -005) and a Special Permission permit (L08 -018). Both applications were expired on December 5, 2008 (see attached letter). The applicant was overcharged for the Special Permission permit in the amount of $240.00. For the SEPA permit, there was an outstanding balance of $200.00 owed to the City of Tukwila. On March 31, 2009, Brett Conrad of PSE submitted a check in the amount of $200 to pay the outstanding balance on the SEPA permit. Brett Conrad of PSE is requesting a refund in the amount of $240.00 for the amount overcharged for the Special Permission permit L08 -018. Please send the refund to PSE at the following address: PSE c/o Brett Conrad EST 06E P.O. Box 90868 Bellevue, WA 98009 -0868 Please call me at (206)431 -3659 or x1659 with any questions...thanks! /110P-1:i° ; - -_ Jaimie Reavis • March 30th, 2009 Jaimie Reavis City of Tukwila 6300 Southcenter Boulevard, Suite #100 Tukwila, WA 98188 MAR 31 2009 RE: PSE 2008 Maintenance — applications for tree removal Dear Jaimie: Please find enclosed a check for $200.00 as requested in your letter of December 5th, 2008. Please process the refund for $240.00 as referenced in your letter. Please let me know if you have any questions or would like additional information. Sincerely, Brett Conrad PSE Vegetation Management Project Manager 253.670.2170 City o Tukwila Jim Haggerton, Mayor Department of Community Development Jack Pace, Director December 5, 2008 Tina Melton Puget Sound Energy RE: PSE 2008 Maintenance — applications for tree removal SEPA Environmental Review (E08 -005) and Special Permission (L08 -018) Dear Tina: An incompleteness letter was sent for the above applications on May 16, 2008, with a list of items that still needed to be received by the City of Tukwila in order for those applications to be deemed complete. A follow -up letter, with additional items needed for City review of your applications, was sent on August 8, 2008 as a result of a meeting we had on August 1, 2008 with Brett Conrad and Tukwila staff. It is Tukwila Department of Community Development (DCD) policy to cancel an incomplete application when the applicant fails to submit additional information required within 90 days following notification from the Department that the application is incomplete. Your applications for SEPA Environmental Review (E08 -005) and a Special Permission (L08 -018) have therefore been canceled. Our records show that there is an outstanding balance of $200 for the SEPA permit. For the Special Permission permit, we owe PSE a refund of $240. Please send in a check for $200, and we will process the refund for $240. Please contact me at (206) 431 -3659 or jreavis @ci.tukwila.wa.us with any questions. Sincerely, • Jaimie Reavis JR Page l of l H:\Special Permission\PSE trees\PSE trees_90 day letter.doc 12/05/2008 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone 206 - 431 -3670 • Fax: 206 - 431 -3665 August 8, 2008 Jim Haggerton, Mayor apartment of Community Development Jack Pace, Director Brett Conrad Puget Sound Energy EST 06E P.O. Box 90868 Bellevue, WA 98009 Cate Burnett Arbor Metrics Solutions 6905 S 228th Street Kent, WA 98032 Kim Peterson Blue Heron Services P.O. Box 393 Index, WA 98256 RE: PSE 2008 Maintenance — applications for tree removal SEPA Environmental Review (E08 -005) and Special Permission (L08 -018) Dear Brett, Cate, and Kim: In May of 2008, we sent you a letter of incomplete application for the land use applications identified above. Items that were requested at that time in order for you to have a complete application included a Shoreline Substantial Development permit application and a $200 outstanding balance for the SEPA application. It was also determined based on a field visit on May 14, 2008 we needed additional technical information (including a table listing the number, type and species of trees to be removed greater than 4" DBH, identified by parcel number) for our review of the project. We are still awaiting submittal of this information, along with the Shoreline Permit application and remaining balance for the SEPA fee. On August 1, 2008, City staff met with Brett Conrad and Kim Peterson to obtain additional information on PSE vegetation management policies and the work proposed in Tukwila. As a result of this meeting, there are a number of items the City of Tukwila is requesting, in addition to those described in the paragraph above, in order to process your applications: 1. Please provide the height of the transmission lines in the areas where you are proposing to remove trees. This includes the sensitive area locations adjacent to the Green River and within the wetland areas to the south, as well as any areas where trees are proposed to be removed from private property. Parcel lines and property ownership should be indicated on the plans, showing whether the trees are located within PSE right -of -way, easements, or private property. 2. Indicate on plans the extent of the wire zone and the extent of the border zone, and indicate which trees are proposed for removal according to the zone in which they're located. For each tree, indicate species, height, and DBH. 3. Indicate on plans the locations of any trees proposed for removal from the danger tree zone that are also located within sensitive areas (including information on species, height, and DBH). JR Page 1 of 2 C:\Documents and Settings\Jaimie- R\Desktop\PSE follow up letter 8 -7.doc 08/08/2008 9:03 AM 6300 Southcenter Boulevard_ Suite #100 • Tukwila_ Wa.chinutnn °RIRR • Phone,- 20h- 471 -7h70 o For- 91)15.411. 7/ohs • • 4. We have reviewed the NERC vegetation standards and do not agree that the extent of vegetation removal as proposed with your applications is required to comply with the NERC standards. The NERC standard requires establishment of vertical clearance between vegetation and transmission wires — not a maximum tree height as PSE has proposed. The NERC standard requires that the vertical clearance take into account local conditions, including line terrain and elevation, species types and growth rates, and an annual vegetation removal plan that considers "all environmental factors" as well as the need to obtain "permissions or permits" from "regulatory authorities" such as the City of Tukwila. PSE's proposed vegetation removal does not address these issues. Finally, the NERC standard expressly acknowledges the possibility that the transmission owner may be "restricted from obtaining the clearances specified," and directs the transmission owner to develop necessary mitigation measures for when that occurs. We assume that those mitigation measures are contained in PSE's Transmission Vegetation Management Program, which we have repeatedly requested but PSE has declined to provide. We have been able to obtain a copy of the latest version of Seattle City Light's vegetation management policy document regarding their work within 230KV rights -of -way. Rather than having a maximum vegetation height, SCL's policy specifies that a vertical clearance between the tops of trees and lines, of 12 to 16 feet, must be maintained. They have a four -year maintenance cycle, except for riparian zones and wetlands, where they acknowledge they may have to return every 1 to 2 years. Given the foregoing, PSE is not correct that the extreme tree removal that it proposes is required by NERC standards. PSE's proposal must comply with City of Tukwila ordinances and applicable state statutes. 5. We also do not believe that the removal of trees as proposed in your applications meets the requirements of the state Shoreline Management Act and our Sensitive Areas Ordinance. 6. Finally, to help us better understand PSE's policies on vegetation management, we again request that you provide us with a copy of the PSE Transmission Vegetation Management Program, to include a complete list of compatible trees. If you have any questions as you are compiling this information for our review, feel free to contact me by phone at (206) 431 -3659 or by email at jreavis @ci.tukwila.wa.us. Sincerely, .� Jaimie Reavis Assistant Planner City of Tukwila cc. Bob C. Sterbank Sandra Whiting Minnie Dhaliwal JR Page 2 of 2 C:\Documents and SettingsJaimie- R\Desktop\PSE follow up letter 8 -7.doc 08/082008 9:03 AM • • 7208 To Whom this may concern This is a print , to be used for our map base, which I am working on acquiring for the PSE submittals related to vegetation management within critical areas and their buffers Geoengineers is producing these maps and can alter them somewhat if a specific request is made. These maps are at 1" = 100' . It has taken weeks to come up with this solution and I am hoping this meets with your approval; but I am still looking for yet another better map idea. If you could please review this map for the adequacy in meeting your specific criteria; we hope to be submitting this scale and type of map for the critical area, shoreline and other related permit requests revolving around the PSE vegetation management needs for 2008. Please let me know your opinion so we can finish up or keep looking for a solution Thanks for your time on this Kim Peterson BHS INC For PSE May 16, 2008 Jim Haggerton, Mayor Department of Community Development Cate Burnett Arbor Metrics Solutions 6905 S 228th Street Kent, WA 98032 NOTICE OF INCOMPLETE APPLICATION Kim Peterson Blue Heron Services, Inc. P.O. Box 393 Index, WA 98256 Jack Pace, Director RE: PSE 2008 Maintenance SEPA Environmental Review (E08 -005) and Special Permission (L08 -018) Applications Dear Cate and Kim: In late March of 2008, we started talking with you about the materials you would need to submit for your application for a special permission decision and SEPA environmental review to remove vegetation underneath PSE power lines according to new federal rules, including the need for a map showing the project area. In early April, the City of Tukwila provided you with an aerial photo on which to mark proposed project areas. On April 21, 2008, four copies of the aerial photo were submitted to the City of Tukwila, one of which had project areas marked by the applicant. Fees for the Special Permission and SEPA applications were submitted to the City of Tukwila on April 22, 2008, at which time a receipt was issued for partial payment of permit fees, with a remainder of $200 in permit fees outstanding at the time the receipt was issued. A review of the marked -up aerial photo, as well as a follow -up visit in the field revealed that the work to be done north of the Family Fun Center will require a Shoreline Substantial Development Permit. It was also determined based on our field visit on May 14, 2008 that we will need additional technical information (including a table listing the number, type and species of trees to be removed greater than 4" DBH, identified by parcel number) for our review of the project. Your application has been found to be incomplete. In order to be a complete application, the following must be submitted to the permit center: 1) Shoreline Permit Application - It is our opinion that it will be difficult for you to qualify for a Shoreline Permit Exemption. If you decide that you would like to apply for an exemption, please look at the criteria for an exemption to the Shoreline JR Page 1 of 2 H:\Special Permission\PSE trees \PSEtreeremoval_incomplete.DOC 05/16/2008 12:39:00 PM 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone: 206 - 431 -3670 • Fax: 206- 431 -3665 Substantial Development Permit requirements. Information on this type of an exemption can be found in RCW Chapter 90.58. Once you decide your approach, you will need to either apply for a Shoreline Exemption or a Shoreline Substantial Development Permit. A Shoreline Permit application is enclosed. Please note there is a notice requirement of 30 days for a Shoreline Substantial Development Permit. 2) The remaining $200 application fee. Upon receipt of these items, the City will re- review them for completeness and will mail you written notification of completeness or incompleteness within 14 days. This application will expire if we do not receive the additional information within ninety days of the date of this letter unless an extension is granted pursuant to Section 18.104.070(E). We are unable to start the public notice period, which includes mailings and posting the site, until your application is complete. There will be a 14 -day comment period for the SEPA and Special Permission applications and a 30 -day comment period for the Shoreline Substantial Development Permit. This will potentially delay your ability to do the work. If you have any questions with this matter you may call me at (206) 431 -3659. Sincerely, Jaimie Reavis Assistant Planner Enclosure: Shoreline Permit Application JR Page 2 of 2 05/16/2008 12:39:00 PM H: \Special Permission \PSE trees \PSEtreeremoval_incomplete.DOC a mie Reavis - PSE project From: Carol Lumb To: Jaimie Reavis Date: 04/22/2008 5:13 pm Subject: PSE project Hi Jaimie: The applicant came in today and paid most of the fees for the project - I incorrectly added up what they owed, the last time they were here so they owe $200. so it's my fault there is money owed. I gave her your card and said you would be the one sending the letter on completeness and that once she received that, then they would have 14 days to get the signs up. I told her that she should check with you on the number of signs that would be needed and that you would notify the sign company with the sign information and installation locations. Let me know if you have any questions. Carol Jaimie Reavis - Fwd: Application Feesw From: Carol Lumb To: Jaimie Reavis Date: 04/21/2008 5:50 pm Subject: Fwd: Application Fees Hi Jaimie: This e-mail relates to the PSE files that Minnie gave you. They finally turned in the needed aerial photos so there are enough to circulate for review. They have not paid the fees yet, and Minnie's thinking that if you are going to be the planner assigned to the project, then it would be better for you to follow up with them if the project is complete, with telling them that we can't do the public notice until we receive the fees. She and I also talked about how many signs they should place along the trail, maybe 3 given how much of the trail they will be working along. Let me know if you want to talk about any aspects of the project. Hopefully I will remember from the earlier discussions with these folks! Carol 1 Jaimie - Reavis - Application Fees From: To: Date: Subject: Hi Cate: Carol Lumb cate.burnett@pse.com 04/21/2008 1:37 pm Application Fees I received the remaining aerial photos today from Kim. I don't think we have received the fees yet and you thought it would just take 2 weeks when the applications were submitted. Can you give me an update on when you expect the check to be ready for submittal? Thanks. Carol Carol Lumb, Senior Planner Dept. of Community Development City of Tukwila 6300 Southcenter Blvd., Suite 100 Tukwila, WA 98188 206 - 431 -3661 (Fax: 206 - 431 -3665) Carol Lumb - Digital File for PSE From: To: Date: Subject: Carol Lumb services @billsblue.com 04/16/2008 1:50 pm Digital File for PSE CC: bheron @seanet.com; cate.burnett @pse.com Hi: I am sending this digital file to you at the request of Blue Heron Services Inc. Please contact Kim Peterson at Blue Heron, phone # 360 - 793 -7767, or e-mail bheron @seanet.com when this file arrives for further information. Thanks. Carol Lumb Carol Lumb, Senior Planner Dept. of Community Development City of Tukwila 6300 Southcenter Blvd., Suite 100 Tukwila, WA 98188 206 - 431 -3661 (Fax: 206 - 431 -3665) Message Carol Lumb - PSE MAP info • • Page 1 of 1 From: "Kim" <bheron @seanet.com> To: <clumb @ci.tukwila.wa.us> Date: 04/04/2008 9:06 AM Subject: PSE MAP info 4 3 0 -8 Greetings Carol could you please send the digital file for PSE to services @billsblue.com they are located in Everett Please include the following information with the file this file is being sent by the City of Tukwila for Blue Heron Services Inc please contact Kim Peterson at Blue Heron phone 360 793 7767 email bheron(a�seanet.com when this file arrives for further information thank you Kim Peterson Blue Heron Services Inc 360 793 7767 file: / /C: \Documents and Settings \CAROL - L\Local Settings\ Temp\ XPGrpWise \47F5EFA5tuk- mail6300 -... 05/15/2008 Carol Lumb - RE: Fast Signs Info • From: "Burnett, Cate - Asplundh" <cate.burnett@pse.com> To: "Carol Lumb" <clumb @ci.tukwila.wa.us> Date: 04/01/2008 10:09 am Subject: RE: Fast Signs Info Will do, thanks Carol! Cate Burnett Utility Forester / Mitigation Specialist PSE /ArborMetrics Solutions, Inc. (206) 718 -8216 From: Carol Lumb [mailto:clumb @ci.tukwila.wa.us] Sent: Thu 3/27/2008 3:29 PM To: Burnett, Cate - Asplundh Subject: Fast Signs Info Hi Cate: Here is the information for Fast Signs: 206 - 575 -2110 Springbrook Business Park 7825 S. 180th Street Kent, WA 98032 You pay the sign fee directly to Fast Signs - the City will provide information to Fast Signs (file number, type of action etc.) once we have determined that there is a complete application. You will want to pay the sign fee within the next couple weeks so that the sign can go up as the Notice of Application is sent out. Carol Carol Lumb, Senior Planner Dept. of Community Development City of Tukwila 6300 Southcenter Blvd., Suite 100 Tukwila, WA 98188 206 -431 -3661 (Fax: 206 -431 -3665) Carol Lumb - RE: Digital File for PSE From: To: Date: Subject: CC: 4 20 08 "Kim" <bheron @seanet.com> "'Carol Lumb "' <clumb @ci.tukwila.wa.us> 04/21/2008 9:15 am RE: Digital File for PSE "duncan" <duncanmedlin @gmail.com> Greetings Carol Thank you for sending the drawing We were able to get a direct copy of the maps in the end: the file transferred had not scale available to the printer and so they were arid to print it without one I have three copies of the map to go with the one you have at this time I will bring it in myself (or have it delivered) on Monday mid to late AM If you are not available this email will appear with the maps If you have any questions please contact me Thanks for all your help Sorry this took so long Kim Peterson 360 793 7767 Original Message From: Carol Lumb [mailto:clumb @ci.tukwila.wa.us] Sent: Wednesday, April 16, 2008 1:50 PM To: services @billsblue.com Cc: cate.burnett@pse.com; bheron @seanet.com Subject: Digital File for PSE Hi: I am sending this digital file to you at the request of Blue Heron Services Inc. Please contact Kim Peterson at Blue Heron, phone # 360 - 793 -7767, or e-mail bheron @seanet.com when this file arrives for further information. Thanks. Carol Lumb Carol Lumb, Senior Planner Dept. of Community Development City of Tukwila 6300 Southcenter Blvd., Suite 100 Tukwila, WA 98188 206 -431 -3661 (Fax: 206 -431 -3665) {Carol Lumb - Fast Signs for PSE: E080005 & LO8 018 Page 1 From: To: Date: Subject: "Burnett, Cate - Asplundh" <cate.burnett@pse.com> <clumb @ci.tukwila.wa.us> 04/01/2008 9:26 am Fast Signs for PSE: E08005 & LO8 018 CC: "Blue Heron Services, Inc." <bheron @premierl.net> Hi Carol, The additional maps will be delivered today. You had mentioned that I would need to get signs within 10 days of the submittal. Please provide me with a phone number and I will move forward. Also, is there a particular location you are requesting the signs be posted? Cate Burnett Utility Forester / Mitigation Specialist PSE /ArborMetrics Solutions, Inc. (206) 718 -8216 Message Carol Lumb - PSE MAP info • • Page 1 of 1 From: "Kim" <bheron @seanet.com> To: <clumb @ci.tukwila.wa.us> Date: 04/04/2008 9:06 AM Subject: PSE MAP info 4 3 0 -8 Greetings Carol could you please send the digital file for PSE to services @billsblue.com they are located in Everett Please include the following information with the file this file is being sent by the City of Tukwila for Blue Heron Services Inc please contact Kim Peterson at Blue Heron phone 360 793 7767 email bheronseanet.com when this file arrives for further information thank you Kim Peterson Blue Heron Services Inc 360 793 7767 file: / /C:\Documents and Settings \CAROL - L\Local Settings\ Temp\ XPGrpWise \47F5EFA5tuk- mail6300 -... 04/15/2008 To: City of Tukwila Projected mitigation totals for 2008 SPRING PSE maintenance Contact: Kim Peterson / Blue Heron Services, Inc. (360) 793 -7767 Calculations for areas of impact within the wetland environments along the railroad/interurban corridor running North to South. Wetland A area: The most Westerly linear wetland area shown on the map defined as an area approx. 2400 lineal feet above the Southern border of the City limits. This area has a portion which expands in size from East to West and comprises a total area of approx. 121,000 sf. The impact area will be limited to that which is adjacent to the kV lines and Interurban trail location )and linear in shape) which will equal less then 1,000 sf. Wetland B This is the wetland area immediately under the kV lines. This area will encompass most of the work required in this project. Total wetland area has been calculated at approximately 5,300 lineal feet of wetland attributes with a few breaks in the contiguous nature of the wetland conditions. Some areas contain dense stands of willow and other species (native and non native) determined to be undesirable within the transmission line right of way. These trees will be killed in place and left standing whenever possible. No soil disturbance which would lead to continued turbidity in areas with flowing water is planned. Total are of impact will be les then100,000 square feet within a general area of over 196,000 square feet. In site walks in February and March 2008 there were some wetland areas noted along the Interurban Trail, throughout the full work area, which did contain waters with a visible flow pattern. It is assumed this is a groundwater action since many of the wetlands are not contiguous in nature and no stream system is noted in this same area. Wetland C This wetland area is noted on the East side of the kV lines and is not affected by this proposed work at this time. Total area within this wetland would exceed 50,000 sf. This wetland area is not contiguous to the work area. Calculations for the impact area of the Green River Urban Shoreline environment: Approximately 650 lineal feet of shoreline falls within areas which will be considered for maintenance. At this time the work is scattered and isolated and the total square footage of work area within the wetland will be approximately 2,500 to 4,000 square feet (within the 40 and 100 foot zone areas). Some clearing work is proposed for an area on the South shoreline, just north of the Family Fun Center, which appears to be a possible mitigation area. Trees have been planted directly within the PSE easement. This area may require additional review for impacts to the mitigation and what implications this will pose. Mitigation for proposed impacts: PSE is prepared to cooperate with the City of Tukwila on any required mitigation on or off site. Due to the complex nature of the clearing and cutting in regards to the FERC / NERC rules planting anything on site (at location of maintenance) will limit replacement species to low growing shrubs and very few trees. Impact total is expected to be approximately 100,000 square feet (2.30 acres) within a lineal, non - continuous, run of about 5,200 feet. On site mitigation could include: Planting of spirea and native rushes and grasses in the wetter and inundated areas Salmonberry, snowberry and other native shrubs in the drier wetland and upland locations. Wetland locations with maximum clearance to the wire could include Dogwood plantings Within the Shoreline area mitigation with shrub would be well within the allowance for vegetation height but not trees (such as those currently existing) will be acceptable for replanting. Replacement of existing mitigated trees (in the Family Fun Center area) will have to be located outside the wire zone (more then 12 feet from the outside wire areas). PSE is more then willing to work with the City for a centrally located mitigation site which meets the City needs and creates a specific location which can be adequately protected and maintained to add habitat values to a particular City owned (or private) site. Maintenance: PSE will need to conduct continued maintenance throughout the system; though the work being proposed at this time is aimed at lessening the repeated maintenance issues and need for yearly vegetation cuts through the removal of the identified species. Please feel free to contact me if you have any questions Kim Peterson Blue Heron Services Inc For PSE 360 793 7767 bheron @seanet.com Newsroom • • PUGET SOUND ENERGY rlfe f' ergs 7b Ao Grapt mow Page 1 of 2 Home Pay Stations & Service Map Contact Us My PSE Account » L0GIN Friday, June 13, 2008 Search Newsroom Puget Sound Energy will spend $12 million on vegetation management in 2007 up from $10 million in 2006 after last year's storm season and other activities BELLEVUE, Wash. -- (October 4, 2007) -- Protecting the natural beauty of the region and providing reliable service is a balancing act for utility companies in the Pacific Northwest requiring Puget Sound Energy to spend more than $12 million this year up from $10 million last year on vegetation management programs to help ensure the power stays on for the company's more than 1 million electric customers. "Washington is known for its beautiful trees and lush vegetation," said Sue McLain, senior vice president of operations for PSE. "This is a blessing and a curse because most of the power outages in our Puget Sound service area are tree - related. The towering trees and their limbs and branches are downed by storms and fall into our lines, resulting in power outages." PSE works throughout the year to manage vegetation by pruning or clearing trees and branches from electric transmission and distribution lines and corridors. After last year's record storm season, this year's efforts have focused heavily in areas that experienced high volumes of tree - related outages, such as Whidbey Island. The expanded 2007 efforts will require PSE to spend $2 million more than last year on storm- related and other vegetation management activities. In recent years, PSE has spent $10 million annually on vegetation management with $500,000 of that amount devoted to planting power line friendly trees. "We are committed to planting the right trees in the right place to balance our need for reliable power and to sustain the region's natural beauty and reap the environmental benefits from having trees in our communities," said McLain. To put the power of reliability into the hands of customers, PSE has developed a vegetation planning guide called "Planning Trees." The print and online handbook helps customers evaluate landscaping opportunities and is a how -to for planting trees and shrubs and tree care solutions. It also lists recommended trees and shrubs to plant near power lines. "Our goal with the 'Planning Trees' guide is to involve customers in landscaping processes that not only will decrease service reliability risks, but also Increase the comfort and value of customers' homes," said McLain. According to the guide, planning trees can be as simple as selecting the right tree for the right location. The key is choosing trees and shrubs that are well- supported by the local climate, do not mature to more than 30 feet in height, are insect and disease resistant, and are aesthetically pleasing. The guide provides a listing of more than 55 tree and shrub species that fit these criteria. To obtain a copy of "Planning Trees" call PSE at 1- 888 -225 -5773 and request the guide or download it here. PSE also conducts the Tree Watch program in which PSE will remove from private property, after receiving permission from the property owner and local government, diseased and dying trees identified by arborists of being at risk of falling onto power lines. And it's done at no cost to the property owner. The service has made a big dent in reducing power outages. Since it began in 1998, the Tree Watch program has cut the number of tree - related power outages by more than 20 percent. If you think you may have a tree or other vegetation that poses a threat to utility lines on your property, contact PSE at the above number and request a Vegetation Management inquiry. PSE will arrange to have an arborist make a site visit within two weeks to determine if the tree in question is currently at risk. PSE is a seven -year Tree Line USA award recipient from The National Arbor Day Foundation. In conjunction with Arbor Day this past April PSE pledged to donate a tree to every Tree City USA city in its service area in recognition of last winter's severe storm season. In addition, PSE will sponsor for the fourth consecutive year, the state's Arbor Day Poster Contest for fifth - graders. Employee volunteers also participate in various community activities to celebrate Arbor Day and demonstrate the company's long- standing commitment to environmental stewardship and neighborhood enhancements. Media Contact http://www.pse.com/newsarchive/Pages/news1004vege.aspx 06/13/2008 NERC's Transmission Vegetatioanagement Program Standard • Sponsored Link Autism Research Findings - www.ianproject.org Explore recent findings from worlds largest online research database TRANSMISSION 2 ►. ISTRIR TION3 NERC's Transmission Vegetation Management Program Standard Nov 1, 2006 12:00 PM Page 1 of 2 PRINTTHIS Powered by ait cab Iity The North American Electric Reliability Council (NERC) has a new standard on transmission vegetation management programs (TVMPs), in effect as of April 7, 2006, that is intended to improve the reliability of the electric transmission systems by: • Preventing outages from vegetation located on transmission rights -of -way (ROW) • Minimizing outages from vegetation adjacent to ROW • Maintaining clearances between transmission lines and vegetation on and along transmission ROW • Universal reporting of vegetation - related outages of the transmission systems to the respective regional reliability organizations (RROs) and NERC. The program applies to transmission system owners, RROs, and all transmission lines operated at 200 kV and above and to any lower- voltage lines designated by the RRO as critical to the reliability of the electric system in the region. Here's how the program works. The transmission owner (TO) must prepare and keep current a formal, documented TVMP. The program must include the TO's objectives, practices, approved procedures and work specifications, and must: • Define a schedule for and the type of ROW vegetation management inspections based on anticipated growth of vegetation and any other environmental operational factors that could impact the transmission lines. • Identify and document clearances between vegetation and overhead, ungrounded supply conductors, taking into consideration transmission line voltage; the effects of ambient temperature on conductor sag under maximum design loading; and the effects of wind velocities on conductor sway. • Create and implement an annual plan for vegetation management work to ensure system reliability. • Report to its RRO, or the RRO designee, sustained transmission line outages http : / /www.printthis.clickability. com/pt/cpt? action =cpt& title= NERC %27s +Transmission... 06/13/2008 NERC's Transmission Vegetation Management Program Standard Page 2 of 2 • determined by the TO to have been caused by vegetation. The RRO will then report outage information quarterly to the NERC, as well as any actions taken by the RRO as a result of any reported outages. For a draft of the entire standard, visit ftp: / /www.nerc.com /pub /sys /all_upol /standards /rs /FAC- 003- 1.pdf. Find this article at: h ttp: / /www. tdwo rld. com /m ag /power_ne res_tra n sm iss ion _vegetation /i ndex. htm I 1 Check the box to include the list of links referenced in the article. © 2008 Penton Media, Inc. All rights reserved. http:// www. printthis .clickability.com/pt/cpt? action =cpt& title= NERC %27s +Transmission... 06/13/2008 Standard FAC -003 -1 — Transmission Vegetation Management Program A. Introduction 1. Title: Transmission Vegetation Management Program 2. Number: FAC -003 -1 3. Purpose: To improve the reliability of the electric transmission systems by preventing outages from vegetation located on transmission rights -of -way (ROW) and minimizing outages from vegetation located adjacent to ROW, maintaining clearances between transmission lines and vegetation on and along transmission ROW, and reporting vegetation - related outages of the transmission systems to the respective Regional Reliability Organizations (RRO) and the North American Electric Reliability Council (NERC). 4. Applicability: 4.1. Transmission Owner. 4.2. Regional Reliability Organization. 4.3. This standard shall apply to all transmission lines operated at 200 kV and above and to any lower voltage lines designated by the RRO as critical to the reliability of the electric system in the region. 5. Effective Dates: 5.1. One calendar year from the date of adoption by the NERC Board of Trustees for Requirements 1 and 2. 5.2. Sixty calendar days from the date of adoption by the NERC Board of Trustees for Requirements 3 and 4. B. Requirements Rl. The Transmission Owner shall prepare, and keep current, a formal transmission vegetation management program (TVMP). The TVMP shall include the Transmission Owner's objectives, practices, approved procedures, and work specifications'. R1.1. The TVMP shall define a schedule for and the type (aerial, ground) of ROW vegetation inspections. This schedule should be flexible enough to adjust for changing conditions. The, inspection schedule shall be based on the anticipated growth of vegetation and any other environmental or operational factors that could impact the relationship of vegetation to the Transmission Owner's transmission lines. R1.2. The Transmission Owner, in the TVMP, shall identify and document clearances between vegetation and any overhead, ungrounded supply conductors, taking into consideration transmission line voltage, the effects of ambient temperature on conductor sag under maximum design loading, and the effects of wind velocities on conductor sway. Specifically, the Transmission Owner shall establish clearances to be achieved at the time of vegetation management work identified herein as Clearance 1, and shall also establish and maintain a set of clearances identified herein as Clearance 2 to prevent flashover between vegetation and overhead ungrounded supply conductors. R1.2.1. Clearance 1 — The Transmission Owner shall determine and document appropriate clearance distances to be achieved at the time of transmission vegetation management work based upon local conditions and the expected time frame in which the Transmission Owner plans to return for future 1 ANSI A300, Tree Care Operations – Tree, Shrub, and Other Woody Plant Maintenance – Standard Practices, while not a requirement of this standard, is considered to be an industry best practice. Adopted by NERC Board of Trustees: February 7, 2006 1 of 5 Effective Date: April 7, 2006 • • Standard FAC -003 -1 — Transmission Vegetation Management Program vegetation management work. Local conditions may include, but are not limited to: operating voltage, appropriate vegetation management techniques, fire risk, reasonably anticipated tree and conductor movement, species types and growth rates, species failure characteristics, local climate and rainfall patterns, line terrain and elevation, location of the vegetation within the span, and worker approach distance requirements. Clearance 1 distances shall be greater than those defined by Clearance 2 below. R1.2.2. Clearance 2 — The Transmission Owner shall determine and document specific radial clearances to be maintained between vegetation and conductors under all rated electrical operating conditions. These minimum clearance distances are necessary to prevent flashover between vegetation and conductors and will vary due to such factors as altitude and operating voltage. These Transmission Owner- specific minimum clearance distances shall be no less than those set forth in the Institute of Electrical and Electronics Engineers (IEEE) Standard 516 -2003 (Guide for Maintenance Methods on Energized Power Lines) and as specified in its Section 4.2.2.3, Minimum Air Insulation Distances without Tools in the Air Gap. R1.2.2.1 Where transmission system transient overvoltage factors are not known, clearances shall be derived from Table 5, IEEE 516 -2003, phase -to- ground distances, with appropriate altitude correction factors applied. R1.2.2.2 Where transmission system transient overvoltage factors are known, clearances shall be derived from Table 7, IEEE 516 -2003, phase -to -phase voltages, with appropriate altitude correction factors applied. R1.3. All personnel directly involved in the design and implementation of the TVMP shall hold appropriate qualifications and training, as defined by the Transmission Owner, to perform their duties. R1.4. Each Transmission Owner shall develop mitigation measures to achieve sufficient clearances for the protection of the transmission facilities when it identifies locations on the ROW where the Transmission Owner is restricted from attaining the clearances specified in Requirement 1.2.1. R1.5. Each Transmission Owner shall establish and document a process for the immediate communication of vegetation conditions that present an imminent threat of a transmission line outage. This is so that action (temporary reduction in line rating, switching line out of service, etc.) may be taken until the threat is relieved. R2. The Transmission Owner shall create and implement an annual plan for vegetation management work to ensure the reliability of the system. The plan shall describe the methods used, such as manual clearing, mechanical clearing, herbicide treatment, or other actions. The plan should be flexible enough to adjust to changing conditions, taking into consideration anticipated growth of vegetation and all other environmental factors that may have an impact on the reliability of the transmission systems. Adjustments to the plan shall be documented as they occur. The plan should take into consideration the time required to obtain permissions or permits from landowners or regulatory authorities. Each Transmission Owner shall have systems and procedures for documenting and tracking the planned vegetation management work and ensuring that the vegetation management work was completed according to work specifications. Adopted by NERC Board of Trustees: February 7, 2006 2 of 5 Effective Date: April 7, 2006 • • Standard FAC -003 -1 — Transmission Vegetation Management Program R3. The Transmission Owner shall report quarterly to its RRO, or the RRO's designee, sustained transmission line outages determined by the Transmission Owner to have been caused by vegetation. R3.1. Multiple sustained outages on an individual line, if caused by the same vegetation, shall be reported as one outage regardless of the actual number of outages within a 24- hour period. R3.2. The Transmission Owner is not required to report to the RRO, or the RRO's designee, certain sustained transmission line outages caused by vegetation: (1) Vegetation - related outages that result from vegetation falling into lines from outside the ROW that result from natural disasters shall not be considered reportable (examples of disasters that could create non - reportable outages include, but are not limited to, earthquakes, fires, tornados, hurricanes, landslides, wind shear, major storms as defined either by the Transmission Owner or an applicable regulatory body, ice storms, and floods), and (2) Vegetation - related outages due to human or animal activity shall not be considered reportable (examples of human or animal activity that could cause a non - reportable outage include, but are not limited to, logging, animal severing tree, vehicle contact with tree, arboricultural activities or horticultural or agricultural activities, or removal or digging of vegetation). R3.3. The outage information provided by the Transmission Owner to the RRO, or the RRO's designee, shall include at a minimum: the name of the circuit(s) outaged, the date, time and duration of the outage; a description of the cause of the outage; other pertinent comments; and any countermeasures taken by the Transmission Owner. R3.4. An outage shall be categorized as one of the following: R3.4.1. Category 1 — Grow -ins: Outages caused by vegetation growing into lines from vegetation inside and/or outside of the ROW; R3.4.2. Category 2 — Fall -ins: Outages caused by vegetation falling into lines from inside the ROW; R3.4.3. Category 3 — Fall -ins: Outages caused by vegetation falling into lines from outside the ROW. R4. The RRO shall report the outage information provided to it by Transmission Owner's, as required by Requirement 3, quarterly to NERC, as well as any actions taken by the RRO as a result of any of the reported outages. C. Measures Ml. The Transmission Owner has a documented TVMP, as identified in Requirement 1. M1.1. The Transmission Owner has documentation that the Transmission Owner performed the vegetation inspections as identified in Requirement 1.1. M1.2. The Transmission Owner has documentation that describes the clearances identified in Requirement 1.2. M1.3. The Transmission Owner has documentation that the personnel directly involved in the design and implementation of the Transmission Owner's TVMP hold the qualifications identified by the Transmission Owner as required in Requirement 1.3. M1.4. The Transmission Owner has documentation that it has identified any areas not meeting the Transmission Owner's standard for vegetation management and any mitigating measures the Transmission Owner has taken to address these deficiencies as identified in Requirement 1.4. Adopted by NERC Board of Trustees: February 7, 2006 3 of 5 Effective Date: April 7, 2006 • • Standard FAC -003 -1 — Transmission Vegetation Management Program M1.5. The Transmission Owner has a documented process for the immediate communication of imminent threats by vegetation as identified in Requirement 1.5. M2. The Transmission Owner has documentation that the Transmission Owner implemented the work plan identified in Requirement 2. M3. The Transmission Owner has documentation that it has supplied quarterly outage reports to the RRO, or the RRO's designee, as identified in Requirement 3. M4. The RRO has documentation that it provided quarterly outage reports to NERC as identified in Requirement 4. D. Compliance 1. Compliance Monitoring Process 1.1. Compliance Monitoring Responsibility RRO NERC 1.2. Compliance Monitoring Period and Reset One calendar Year 1.3. Data Retention Five Years 1.4. Additional Compliance Information The Transmission Owner shall demonstrate compliance through self - certification submitted to the compliance monitor (RRO) annually that it meets the requirements of NERC Reliability Standard FAC- 003 -1. The compliance monitor shall conduct an on- site audit every five years or more frequently as deemed appropriate by the compliance monitor to review documentation related to Reliability Standard FAC- 003 -1. Field audits of ROW vegetation conditions may be conducted if determined to be necessary by the compliance monitor. 2. Levels of Non - Compliance 2.1. Level 1: 2.1.1. The TVMP was incomplete in one of the requirements specified in any subpart of Requirement 1, or; 2.1.2. Documentation of the annual work plan, as specified in Requirement 2, was incomplete when presented to the Compliance Monitor during an on -site audit, or; 2.1.3. The RRO provided an outage report to NERC that was incomplete and did not contain the information required in Requirement 4. 2.2. Level 2: 2.2.1. The TVMP was incomplete in two of the requirements specified in any subpart of Requirement 1, or; 2.2.2. The Transmission Owner was unable to certify during its annual self - certification that it fully implemented its annual work plan, or documented deviations from, as specified in Requirement 2. 2.2.3. The Transmission Owner reported one Category 2 transmission vegetation - related outage in a calendar year. Adopted by NERC Board of Trustees: February 7, 2006 Effective Date: April 7, 2006 4 of 5 • • Standard FAC -003 -1 — Transmission Vegetation Management Program 2.3. Level 3: 2.3.1. The Transmission Owner reported one Category 1 or multiple Category 2 transmission vegetation - related outages in a calendar year, or; 2.3.2. The Transmission Owner did not maintain a set of clearances (Clearance 2), as defined in Requirement 1.2.2, to prevent flashover between vegetation and overhead ungrounded supply conductors, or; 2.3.3. The TVMP was incomplete in three of the requirements specified in any subpart of Requirement 1. 2.4. Level 4: 2.4.1. The Transmission Owner reported more than one Category 1 transmission vegetation - related outage in a calendar year, or; 2.4.2. The TVMP was incomplete in four or more of the requirements specified in any subpart of Requirement 1. E. Regional Differences None Identified. Version History Version Date Action Change Tracking Version 1 TBA 1. Added "Standard Development 01/20/06 Roadmap." 2. Changed "60" to "Sixty" in section A, 5.2. 3. Added "Proposed Effective Date: April 7, 2006" to footer. 4. Added "Draft 3: November 17, 2005" to footer. Adopted by NERC Board of Trustees: February 7, 2006 5 of 5 Effective Date: April 7, 2006 1 u- h-Q-- - ey\ K4-:rj:r\ (-7 v-9":\e— c9� \ 3/2008 BRIEF NARRATIVE UPDATE FOR FERC & NERC REQUIREMENTS FOR OVERHEAD TRANSMISSION LINE MAINTENANCE For more details review the on line data at www.nerc.com/pub /sys /all upol /standards /sar /FAC- MAR n, 20081 .r These recent, more stringent, FERC/NERC regulations require more specific maintenance procedures and protocols for the regular maintenance work conducted. These requirements include clear and concise definitions for trees species which will not be allowed within the transmission line right of ways and must be removed. The rule update is driven by the blackouts on the east coast which came to everyone's in 2003. Additionally the federal ruling is considered a matter of national security. Power line outages not only disrupt service but can be potentially hazardous to the general population. It has always been part of the routine maintenance protocols of PSE to review the conditions of the corridors in which lines are maintained and remove potential hazards as necessary. Regular maintenance circuit reviews are cyclic and each line in this area comes up for assessment every 3 to 5 years. In recognition of the federal mandates PSE has set specific goals which will improve over -all reliability and meet all Federal mandates within the next few years. Compliance with new FREC/NERC rules will be achieved by adhering to the newly standardized protocols PSE has created throughout the management corridors. The new protocol identifies tree species for removal based on a DBH (diameter at breast height) and projected height; based on growth standards for the species. The adopted protocol requires allowing only those species which are less then 6 inches DBH and determined to attain a maximum mature height of less then 15 feet. The new FERC/NERC rules call for two different Clearances from overhead transmission lines (distance of vegetation from the conductor) which must be developed by each owner of kV 230 lines. Clearance 1 is the distance which must be obtained at time of regular maintenance. Since our native species have several growth rates and mature heights, PSE has determined the need to develop Clearance 1 based on the maximum mature height of trees which are to be allowed within the Right of way and wire zone (12 feet to each side of the actual over head wire). After review of several Washington State native tree and shrub species, PSE has adopted 15 feet as the maximum allowed height in the corridor of maintenance. This process has also identified what distinct species will be allowable; this information will be coming out in a separate handout developed by PSE and sent to all parties with interest, responsible for review criteria and/or agencies). 1 The 15 foot standard is commonly used when considering height restrictions an the areas of power lines. The other Washington State owner of 230kV lines in this area is BPA. BPA uses 14 feet as the height maximum for all trees in their maintenance areas. Nationwide many other kV230 lines allow maximum 15 foot trees within the wire line areas. Clearance 2 determines the area which makes up the allowed distance between any vegetation and the transmission conductors; this distance must be kept clear at all times. PSE has determined the Clearance 2 allowed distance (which is to prevent flashover on 230 kV lines ) to be 6.8 feet. The federal guidelines for determining the Category 2 distance formula has been developed by IEEE (International Electrical and Electronics Engineers) and applied to adjust for the terrain in the area of the transmission lines. Based on this calculation, the distance for the type 2 Clearance equals 6.8 feet system wide. This criteria then established the area in which no vegetation is ever allowed regardless of the cyclic rotation of maintenance at the specific site. The design of 230kV transmission lines create a minimum ground clearance (as defined by the NESC / National Electrical Safety Code) between 22 and 25 feet at all times. When this minimum ground clearance height is juxtaposed to the minimum 6.8 foot type 2 Clearance, the result is close to the 15 feet maximum vegetation height allowance proposed by PSE . While review of any one specific area of the transmission line may result in a somewhat different final maximum and minimum height and separation distance; PSE must develop a final protocol which is followed system wide without variation. • • Infrastructure Conditions 14. Infrastructure Conditions 14.1 Industry Practices kEMQ Vegetation management, access road management and system hardening are critical elements for many utilities that face the potential of excessive winds or other tree related problems. Vegetation management has always been a high priority of electric transmission and distribution utilities. The majority of US electric utilities have very active programs and in some cases are required to report their programs to the regulators. Transmission vegetation management generally consists of three parts. First, is to ensure the rights of way (ROW) are trimmed to keep trees and branches well outside the conductors. This usually entails trimming at the margins of the ROW. Second, is the vegetation control inside the ROW to prevent new trees from growing in the ROW and to preserve vehicular access to the facilities. Third is the management of danger trees. These are trees located outside of the right of way, but are sufficiently tall enough to make contact should they fall and have some structural defect. Utilities have formal programs to remove such trees before they become a problem. Transmission access road management ensures access to cross - country transmission corridors. The leading practice is to maintain these roads so that crews have ready access to the transmission system. Electric system hardening is a new leading practice designed to harden those portions of a distribution system subject to extreme winds. The Florida utilities have done a substantial amount of work in this area. 14.2 PSE Practices PSE has a good vegetation management program, with well defined cycles for both transmission and distribution circuits. Most of the $8 million is spent on maintaining the distribution system tree clearances. PSE has a well- respected danger tree program called "TreeWatch." This program has been an aggressive effort to remove danger trees from the rights -of -way and has been very effective. In addition to TreeWatch, PSE has a number of reliability improvement programs in place that are a type of system hardening. These include, among other actions, installation of tree wire, animal guards, and conversion of some overhead lines to underground. The company has not devoted significant effort to system hardening, however, in terms of evaluating different design and construction methods and materials on the transmission and distribution systems; although, the majority of new distribution construction is underground. Puget Sound Energy 14 -1 Proprietary Storm Restoration Review July 2, 2007 • • Infrastructure Conditions 14.3 Conclusions KEMA k 14.3.1 The narrow rights -of -way with heavily vegetated areas immediately adjacent were significant contributors to the infrastructure damage and the extended restoration times experienced in some cases. KEMA noted that PSE transmission rights -of -way are very narrow compared to other utilities across the country. The local trees are generally much taller than the physical transmission structures. These two conditions create a potentially significant problem for the transmission system. The potential for out of ROW tree contact is much greater during storms like the one of December 14 -15. PSE recognizes the problem but is limited in its ability to overcome the strong public sentiment around the local vegetation and the limited area available wider for rights -of -way due to growth and development. KEMA performed a number of field observations to better understand PSE's situation. The team concluded that: • There is good evidence that PSE's distribution tree trimming program is effective. In spite of narrow rights -of -way boundaries that are extremely close to lines, the KEMA team generally found no over hanging branches; • Trees are significantly taller than both the distribution or transmission lines and structures; • Many trees lining circuits were in subdivision buffers making them much more susceptible to high wind damage; and • The combination of extremely tall trees relatively close to T &D facilities and the lack of wind breaks in some areas make trees very vulnerable to wind - caused failures. This was particularly true when KEMA considered the fact that there were abnormally high levels of rain prior to the December 14 -15 storm, leaving the earth much softer than usual and impacting the tree stability. PSE's 2006 reliability results (Exhibit 14 -1) indicate that 25% of all non -storm customer outages are tree related. Puget Sound Energy 14 -2 Proprietary Storm Restoration Review July 2, 2007 Infrastructure Conditions N4 KEMA "k 440K001q06006g9N4 2006 Customer Non- Storm Outages by Cause Accident, Other w ith Ares 2% Bird or Animal 14% Car Pole Accident 2% Tree -On Right of Way/ 13% Tree -Off Right of Way 12% Other Cause 12% Equipment Failure 45% Exhibit 14 -1: 2006 Customer Outages by Cause 14.3.2 PSE's TreeWatch program has been effective in mitigating tree risk; however, all vegetation management issues will not be rectified with a business -as -usual approach. Danger tree programs generally focus on the transmission system and its rights -of -way (ROW). Danger trees have the following typical characteristics: they are tall, are located outside of the ROW, are diseased or otherwise damaged, and if they were to fall into the ROW, could make contact with the transmission line or structure. Most utilities owning transmission systems have a formal program to identify, purchase and remove such trees. PSE has an extremely active and effective danger tree program known as TreeWatch. When first initiated TreeWatch was funded through capital deferral with regulatory approval and funded at approximately $10 million per year for five years. It is now funded as an O &M program at $2 million per year. This is in addition to the standard vegetation program funding of $8 million per year. Within the TreeWatch Program, PSE in 2006 cleared trees around 600 miles of T &D lines and removed 13,853 danger trees.108 108 Review and analysis of PSE's 2006 Annual Reliability Report Puget Sound Energy 14 -3 Proprietary Storm Restoration Review July 2, 2007 • • Infrastructure Conditions KEMQ k Transmission corridors are established to allow crews access to lines, prevent trees and other vegetation from damaging facilities, and for public safety. PSE's transmission is primarily 115kV with some 230kV. Based on utility industry common practice guidelines the ROW for 115kV should be 100 feet and the 230KV should be between 125 and 200 feet depending on structure type and other conditions. The team noted that the types of trees growing in and around PSE's service territory tend to grow to heights 1.5 to 1.7 times the height of the transmission system. Our observations of PSE's storm impacted transmission lines show that the ROW width for many lines is inconsistent with the above mentioned guidelines. KEMA identified two direct concerns with this finding: • The potential for line damage caused by trees falling into lines during severe weather as experienced in the December 14 -15 storm is far greater, and contributed to the loss of 85 transmission lines; and • The potential for tree incursion is significantly increased with narrow ROWs such as found at PSE. Exhibit 14 -2 and Exhibit 14 -3 demonstrate our concerns. Exhibit 14 -2: North King County Right -of -Way Vegetation Puget Sound Energy 14 -4 Storm Restoration Review Proprietary July 2, 2007 Infrastructure Conditions Exhibit 14 -3: North King County Right -of -Way Growth 14.3.3 Increasing PSE's vegetation management program will not address the impacts of narrow rights -of -way. Vegetation management programs in electric utilities are designed to ensure that trees and their branches are kept a safe distance from T &D lines and structures and thus, prevent accidental contact that can either cause lines to lose service or damage equipment. This is done by cycle trimming of circuit corridors based on the average growth rate of the native tree and brush population. The majority of utilities have formal programs that are annually funded. PSE follows a distribution cycle trim program with approximately 50% of the system on a four -year cycle and 50% on a six year cycle, with cycle times based on vegetation type. For distribution voltages, desired clearance is based on a four or six year cycle based on average vegetation growth. Management states PSE gets desired clearance 95% of the time. The transmission system is maintained on a three -year cycle. Vegetation management for transmission ROW is designed by voltage class, as the higher the voltage the taller the structure. PSE's transmission guidelines are as follows: • For 230 kV, the desired clearance is 40 feet under the conductor, 15 feet for side clearance for conifers, and 20 feet for deciduous varieties. Puget Sound Energy 14 -5 Proprietary Storm Restoration Review July 2, 2007 • • Infrastructure Conditions KEMA-." • For 115 kV, the right of way obtained by the company determines the amount of clearing they can accomplish. The 115 -kV circuits in urban areas are on single wood poles along roadways, often with underside -built distribution. In most cases, the 115 -kV line is encroached on roadway ROW and the clearing zone is limited by private property at the edge of roadway ROW. Due to PSE's ROW limitations, caused by regional, cultural, and political considerations, vegetation management is primarily a safety program as opposed to a reliability program. Industry norms are to maintain rights -of -way for both safety and reliability; however, at PSE the narrow rights -of -way and limited rights for private property trimming limit the effect that can be realized on system reliability. It should be noted, however, that PSE reliability indices fall into the first or second quartile of utilities in the country as reported in an IEEE reliability survey.109 As noted earlier, the PSE 2005 System Performance Annual Review reports that 40% of non -storm customer outage minutes were tree caused. Because of limitations PSE faces in right -of -way vegetation maintenance, other programs have been adopted to reduce the number of customer outage minutes caused by trees. As part of an Overhead Outage Reduction Program the company also considers actions such as the replacement of aging small wire, installation of covered conductor (tree wire), and animal guard installations to help reduce outages. Placing existing lines underground lines is also an option but is generally cost prohibitive. Statistics from 1997 indicated that 60% of tree- caused outages were from trees more than 15 feet from the affected line. About 13.5% of tree caused outages were due to tree growth in the line. Of trees falling into lines, 30% were from broken tree trunks compared to 31% from uprooted trees.11° Obstacles to effective tree maintenance include local government ordinances that require permitting or other approvals prior to cutting street trees, private property rights, and PSE ROW management practices that have included less than full exercise of company rights. As stated earlier in this report, the majority of significant damage caused to PSE's T &D facilities was due to trees falling into the lines from outside PSE rights -of -way. KEMA is extremely concerned that the issues noted above may result in similar damage should PSE experience another event the magnitude of the December 14 -15 storm. 14.3.4 Current level of funding for transmission right -of -way maintenance is inadequate for reducing risk of damage to the facilities in similar storms. On transmission corridors, vegetation management is designed to keep clear paths open for vehicles to access transmission facilities and is generally considered an industry leading practice. 109 IEEE Distribution Subcommittee Working Group on System Design, 2004 Reliability Survey 110 KEMA Interview WLS01 Puget Sound Energy 14 -6 Proprietary Storm Restoration Review July 2, 2007 • • Infrastructure Conditions PSE spends $8 million annually on its program, but only $1.75 million is devoted to transmission. The annual performance indicator of cost of trimming per circuit mile has remained constant since 2000. PSE has already begun a special 230kV vegetation management program designed to remove ROW trees with a mature height of greater than 15 feet that will cost about $7.5 million and cover approximately 327 miles of right -of- way."' 14.3.5 The lack of access road maintenance resulted in delays to transmission system repairs. PSE does not allocate any money to develop and maintain access roads to transmission lines located off normal roads. Access to transmission corridors is critical for two reasons: • PSE must be able to access structures for routine inspection; and • PSE must have unfettered access during emergencies to assess damage and make necessary repairs. Electric utilities have formal programs to manage vegetation inside and along the rights -of -way and attendant access roads. Based on physical inspection of the access roads and the ROW in some of the hardest hit areas, PSE could do better controlling vegetation for vehicle access. As a result, transmission crews could not easily access many damaged transmission lines, leading to a number of delays that lengthened the overall restoration time of the transmission system. According to several individuals with the responsibility of repairing the transmission system, the delays ranged from several hours to as much as one day as bulldozers were needed to cut paths and pull trucks to damaged facilities. Exhibit 14 -4 and Exhibit 14 -5 illustrate the extensive growth on the ROW and access roads. 111 KEMA Interview RG22 Puget Sound Energy 14-7 Storm Restoration Review Proprietary July 2, 2007 • • Infrastructure Conditions Exhibit 14-4: Vegetation Impeding ROW Access Exhibit 14 -5: Vegetation Impeding ROW Access Puget Sound Energy Storm Restoration Review 14 -8 Proprietary July 2, 2007 • • Infrastructure Conditions 14.3.6 Putting existing lines underground will not eliminate outages. KEMA It is a common perception that putting distribution systems underground will insulate utilities from the type of wind -tree problems experienced during the December 14 -15 storm. However, in order for underground facilities to prevent or minimize damage from wind storms, the entire transmission and distribution system would need to be underground. The transmission system outages experienced in this storm interrupted power to all distribution circuits the transmission lines supplied, including the underground circuits. In order for underground facilities to have made a difference, the transmission system would have to have been underground. A recent study by KEMA for a state regulatory agency documented the cost of undergrounding new transmission lines at $10 -$20 million per circuit mile, depending upon line voltage and type of construction used. Additionally, environmental regulations and required permitting for construction of this type often drive costs even higher. While the concept of undergrounding facilities has merits, a number of mitigating factors have to be considered: • PSE currently has about 47% of its distribution system underground; • PSE experienced some underground outages during the storm; • About 30 gas line breaks during the storm could be directly attributed to up- rooted trees demonstrating the vulnerability of underground utilities to windstorms and tree damage; • The cost to place the existing distribution system underground would be costly for customers. Industry studies document the cost to convert overhead distribution facilities to underground to be eight to ten times the cost of new overhead construction. Costs for new underground are estimated at five to seven times the cost of new overhead construction.12 • Maintenance and operation of underground systems is more expensive. Also outages on underground systems are on average longer than overhead outages. Placing distribution lines underground during new construction can be cost - effective because the utility and customer share the installation cost. Typically, all new residential and commercial developments are built underground. The developer /owner usually provides the trench and backfill services while the utility provides the cable, equipment and connections. Currently, it is estimated that over 97% of PSE's new distribution construction is underground. It is KEMA's understanding that PSE is willing to consider conversion of existing facilities to underground. Such consideration would include provision that the cost differential can be managed in a way that protects customers from extraordinary rate impact and at the same time protects the financial integrity of PSE. Throughout the US utility industry there is a concerted effort underway to develop methods to strengthen electric infrastructure against storms. Undergrounding lines is only one of many options to be considered in this effort. Utilities, like PSE, are challenged to find the best mix of engineering standards, construction methods, and materials that will provide a 72 "Out of Sight, Out of Mind" A Study on the Cost and Benefits of Undergrounding Overhead Power Lines, Edison Electric Institute, July 2006 Puget Sound Energy 14 -9 Proprietary Storm Restoration Review July 2, 2007 • • Infrastructure Conditions stronger system for the most reasonable cost. In an effort to maintain a reasonable rate structure, many options should be considered and evaluated both technically and financially. For example, a study in North Carolina showed that undergrounding all existing distribution lines in the state would take approximately 25 years and cost over $40 billion. This increase in the value of the distribution facilities in service would require a rate increase on the order of 125 %.13 For an investment of much less money, significant changes could be made to an overhead distribution system that would yield major improvements in reliability both in daily operations and storm conditions. Another concern with undergrounding electric lines is that many other utilities use the electric system poles. If electric lines are placed underground, the telephone, CAN, and other communications lines are either forced underground or required to assume ownership of the existing poles. Some estimates place the resulting cost increase in services from these providers as high as 25 %. Again, the net effect is an increase in cost to all customers of those systems. 14.4 Recommendations 14.4.1 Enhance PSE's transmission vegetation management policy and standards for ROW width. KEMA recognizes that PSE as other utilities in the region face a daunting task of trying to get wider ROWs and increased vegetation management programs due to political and social pressures. Balancing these external concerns with the need to continue to provide safe and reliable electric service will require a different and concerted effort on the part of PSE. KEMA recommends that PSE take the following actions: • Work with other utilities in the region including BPA to foster change in both public perception and regulatory policy to create new regulations to support improved reliability consistent with the new NERC guidelines; • Map the most frequently and severely storm impacted areas of the transmission system; • Formalize a plan to broaden ROWs in particularly hard hit areas; • Expand PSE's Tree Watch Program to cover these difficult areas; • Develop plans to increase vegetation management activities in these critical weak spots by; and • Ensure that all cross country ROWs have adequate paths to permit moving equipment inside the ROW. 14.4.2 Aggressively develop and maintain cross country transmission access roads. Lack of access roads created delays in transmission restoration. KEMA recommends that PSE take the following actions: 13 "Out of Sight, Out of Mind" A Study on the Cost and Benefits of Undergrounding Overhead Power Lines, Edison Electric Institute, July 2006 Puget Sound Energy 14 -10 Proprietary Storm Restoration Review July 2, 2007 • • Infrastructure Conditions J • Continue PSE's efforts to catalog all existing access roads; • Develop a comprehensive access road program for cross country transmission lines. The program should: - Create a rating system for access road conditions; - Identify those access roads requiring culvert construction; - Develop a program to upgrade those access roads used to get to the hardest hit or frequently hit corridors; and - Prepare and fund an access road maintenance program. • Coordinate the access road program with the vegetation management program so critical sections of transmission corridors are fully accessible. 14.4.3 Evaluate hardening opportunities for both transmission and distribution. In 2006 PSE spent in excess of $180 million to repair or rebuild portions of its T &D systems. This level of expenditure for repair of storm damage may justify further investment in damage prevention. KEMA recommends that PSE undertake the following actions: • Conduct a system hardening study to determine: - Additional opportunities for under grounding; - The use of different towers in particularly hard hit areas; and - Match material and design standards to the region's weather conditions Puget Sound Energy 14 -11 Storm Restoration Review Proprietary July 2, 2007 • Scope • • Transmission Vegetation Management Requirements 0400.4200 This standard covers the vegetation clearance requirements for transmission lines. Environmental Requirements Temporary erosion and sediment control requirements must be identified and appropriate controls installed prior to beginning any vegetation management procedure. Refer to local jurisdiction requirements. Vegetation Management Zones There are three vegetation management zones on transmission rights -of -way. Wire Zone Border Zone Danger Tree Zone The wire zone is located beneath the conductors, and extends a few feet on either side of the conductor. In this zone, all trees maturing at a height of greater than 15 feet shall be removed, unless terrain conditions allow for 40 feet of clearance from the conductors. Vegetation shall not be allowed to encroach within 6.8 feet of any transmission line. The border zone is located along those portions of the right of way not directly under the conductors. In this zone is a diverse plant community of herbaceous and woody plants, including shrubs and small trees. This is accomplished through the selective removal of incompatible trees. In this zone, coniferous trees that can not be pruned for 15 feet of clearance from the conductors shall be removed. Deciduous trees that can not be pruned for 20 feet of clearance from the conductors shall be removed. No vegetation shall be allowed to overhang a transmission conductor. Vegetation shall not be allowed to encroach within 6.8 feet of any transmission line. The danger tree zone is located in the forest cover adjacent to the right of way. The vegetation management objective in this zone is to identify and removed trees that are likely to fall within the next maintenance cycle period (common defmition). The key is the identification of trees in the adjacent stand that are predisposed to falling, thus making them likely to come in contact with the conductors. The goal in the danger tree zone is to maintain reliability over the course of the three year cycle. Clearance Requirements for Existing Construction For existing construction: • Clearing requirements will conform to existing and/or original clearing limits. • All distances are measured from the conductor. Clearing Zone For existing construction, the clearing zone represents a combination of the border and wire zones. 02007 Puget Sound Energy, Inc. Effective on: 07/18/07 Canceling: 06/02/07 Page 1 of 5 • • Transmission Vegetation Management Requirements Figure 1 HPA Cross Country Construction 0400.4200 Figure 2 H -Frame Cross Country Construction Figure 3 Steel Tower Cross Country Construction Effective on: 07/18/07 Canceling: 06/02/07 Page 2 of 5 ©2007 Puget Sound Energy, Inc. Figure 4 • • Transmission Vegetation Management Requirements Roadside Construction 0400.4200 Clearance Requirements for New Construction For new construction: • Clearing zone width may vary according to span length to compensate for conductor movement at midspan. • All distances are measured from the conductor. Clearing Zone For new construction, the clearing zone represents a combination of the border and wire zones, even though the border and wire zone clearances are identified. Figure 5 HPA Cross Country Construction ©2007 Puget Sound Energy, Inc. Effective on: 07/18/07 Canceling: 06/02/07 Page 3 of 5 • • Transmission Vegetation Management Requirements Figure 6 H -Frame Cross Country Construction 0400.4200 Figure 7 Steel Tower Cross Country Construction Effective on: 07/18/07 Canceling: 06/02/07 Page 4 of 5 ©2007 Puget Sound Energy, Inc. Figure 8 Transmission Vegetation Management Requirements Roadside Construction 0400.4200 Figure 9 Clearing requirements, multiple lines 115 -230 kV References The following Puget Sound Energy document applies to this standard: PSE Transmission Vegetation Management Program 02007 Puget Sound Energy, Inc. Effective on: 07/18/07 Canceling: 06/02/07 Page5of5 Standard FAC -003 -1 — Transmission Vegetation Management Program Standard Development Roadmap This section is maintained by the drafting team during the development of the standard and will be removed when the standard becomes effective. Development Steps Completed: 1. The standard authorization request (SAR) was posted for industry comment in May 2004. 2. A standard drafting team was selected in July 2004. 3. The standard drafting team received comments on the SAR from nearly 60 separate entities. 4. The proposed standard documents were posted for comment in January 2005. 5. Draft 2 of the standard was posted for comment in June 2005 6. Draft 3 of the standard posted for 30 day pre - ballot review from November 17— December 19, 2005. 7. Initial ballot December 19, 2005 —January 6, 2006. 8. Recirculation Ballot January 23, 2006 —January 27, 2006. Description of Current Draft: Final draft. Future Development Plan: Draft 3 Page 1 of 7 (Proposed) Effective Date: TBA Anticipated Actions Anticipated Date 1. Board Adoption February 6, 2006 2. Proposed Effective Date April 7, 2006 Draft 3 Page 1 of 7 (Proposed) Effective Date: TBA • Standard FAC -003 -1 — Transmission Vegetation Management Program Definitions of Terms Used in Standard This section includes all newly defined or revised terms used in the proposed standard. Terms already defined in the Reliability Standards Glossary of Terms are not repeated here. New or revised definitions listed below become approved when the proposed standard is approved. When the standard becomes effective, these defined terms will be removed from the individual standard and added to the Glossary. Altitude Correction Factor: A multiplier applied to specify distances, which adjusts the distances to account for the change in relative air density (RAD) due to altitude from the RAD used to determine the specified distance. Altitude correction factors apply to both minimum worker approach distances and to minimum vegetation clearance distances. Fire Risk: The likelihood that a fire will ignite or spread in a particular geographic area. Flashover: An electrical discharge through air around or over the surface of insulation, between objects of different potential, caused by placing a voltage across the air space that results in the ionization of the air space. IEEE: Institute of Electrical and Electronics Engineers, Inc. Vegetation Inspection: The systematic examination of a transmission corridor to document vegetation conditions. Operating Voltage: The voltage level by which an electrical system is designated and to which certain operating characteristics of the system are related; also, the effective (root- mean- square) potential difference between any two conductors or between a conductor and the ground. The actual voltage of the circuit may vary somewhat above or below this value. Rated Electrical Operating Conditions: The specified or reasonably anticipated conditions under which the electrical system or an individual electrical circuit is intend/designed to operate. Right -of -Way (ROW): A corridor of land on which electric lines may be located. The Transmission Owner may own the land in fee, own an easement, or have certain franchise, prescription, or license rights to construct and maintain lines. Sustained Outage: The deenergized condition of a transmission line resulting from a fault or disturbance following an unsuccessful automatic reclosing sequence and/or unsuccessful manual reclosing procedure. Transmission Line: A system of structures, wires, insulators and associated hardware that carry electric energy from one point to another in an electric power system. Lines are operated at relatively high voltages varying from 69 kV up to 765 kV, and are capable of transmitting large quantities of electricity over long distances. Vegetation: All plant material, growing or not, living or dead. Draft 3 Page 2 of 7 (Proposed) Effective Date: TBA 4. Standard FAC -003 -1 — Transmission Vegetation Management Program A. Introduction 1. Title: Transmission Vegetation Management Program 2. Number: FAC -003 -1 3. Purpose: To improve the reliability of the electric transmission systems by preventing outages from vegetation located on transmission rights -of -way (ROW) and minimizing outages from vegetation located adjacent to ROW, maintaining clearances between transmission lines and vegetation on and along transmission ROW, and reporting vegetation - related outages of the transmission systems to the respective Regional Reliability Organizations (RRO) and the North American Electric Reliability Council (NERC). 4. Applicability: 4.1. Transmission Owner. 4.2. Regional Reliability Organization. 4.3. This standard shall apply to all transmission lines operated at 200 kV and above and to any lower voltage lines designated by the RRO as critical to the reliability of the electric system in the region. 5. Effective Dates: 5.1. One calendar year from the date of adoption by the NERC Board of Trustees for Requirements 1 and 2. 5.2. Sixty calendar days from the date of adoption by the NERC Board of Trustees for Requirements 3 and 4. B. Requirements Rl. The Transmission Owner shall prepare, and keep current, a formal transmission vegetation management program (TVMP). The TVMP shall include the Transmission Owner's objectives, practices, approved procedures, and work specifications'. R1.1. The TVMP shall define a schedule for and the type (aerial, ground) of ROW vegetation inspections. This schedule should be flexible enough to adjust for changing conditions. The inspection schedule shall be based on the anticipated growth of vegetation and any other environmental or operational factors that could impact the relationship of vegetation to the Transmission Owner's transmission lines. R1.2. The Transmission Owner, in the TVMP, shall identify and document clearances between vegetation and any overhead, ungrounded supply conductors, taking into consideration transmission line voltage, the effects of ambient temperature on conductor sag under maximum design loading, and the effects of wind velocities on conductor sway. Specifically, the Transmission Owner shall establish clearances to be achieved at the time of vegetation management work identified herein as Clearance 1, and shall also establish and maintain a set of clearances identified herein as Clearance 2 to prevent flashover between vegetation and overhead ungrounded supply conductors. R1.2.1. Clearance 1 — The Transmission Owner shall determine and document appropriate clearance distances to be achieved at the time of transmission vegetation management work based upon local conditions and the expected ' ANSI A300, Tree Care Operations — Tree, Shrub, and Other Woody Plant Maintenance — Standard Practices, while not a requirement of this standard, is considered to be an industry best practice. Draft 3 Page 3 of 7 (Proposed) Effective Date: TBA • Standard FAC -003 -1 — Transmission Vegetation Management Program time frame in which the Transmission Owner plans to return for future vegetation management work. Local conditions may include, but are not limited to: operating voltage, appropriate vegetation management techniques, fire risk, reasonably anticipated tree and conductor movement, species types and growth rates, species failure characteristics, local climate and rainfall patterns, line terrain and elevation, location of the vegetation within the span, and worker approach distance requirements. Clearance 1 distances shall be greater than those defined by Clearance 2 below. R1.2.2. Clearance 2 — The Transmission Owner shall determine and document specific radial clearances to be maintained between vegetation and conductors under all rated electrical operating conditions. These minimum clearance distances are necessary to prevent flashover between vegetation and conductors and will vary due to such factors as altitude and operating voltage. These Transmission Owner - specific minimum clearance distances shall be no less than those set forth in the Institute of Electrical and Electronics Engineers (IEEE) Standard 516 -2003 (Guide for Maintenance Methods on Energized Power Lines) and as specified in its Section 4.2.2.3, Minimum Air Insulation Distances without Tools in the Air Gap. R1.2.2.1 Where transmission system transient overvoltage factors are not known, clearances shall be derived from Table 5, IEEE 516 -2003, phase -to- ground distances, with appropriate altitude correction factors applied. R1.2.2.2 Where transmission system transient overvoltage factors are known, clearances shall be derived from Table 7, IEEE 516 -2003, phase -to -phase voltages, with appropriate altitude correction factors applied. R1.3. All personnel directly involved in the design and implementation of the TVMP shall hold appropriate qualifications and training, as defined by the Transmission Owner, to perform their duties. R1.4. Each Transmission Owner shall develop mitigation measures to achieve sufficient clearances for the protection of the transmission facilities when it identifies locations on the ROW where the Transmission Owner is restricted from attaining the clearances specified in Requirement 1.2.1. R1.5. Each Transmission Owner shall establish and document a process for the immediate communication of vegetation conditions that present an imminent threat of a transmission line outage. This is so that action (temporary reduction in line rating, switching line out of service, etc.) may be taken until the threat is relieved. R2. The Transmission Owner shall create and implement an annual plan for vegetation management work to ensure the reliability of the system. The plan shall describe the methods used, such as manual clearing, mechanical clearing, herbicide treatment, or other actions. The plan should be flexible enough to adjust to changing conditions, taking into consideration anticipated growth of vegetation and all other environmental factors that may have an impact on the reliability of the transmission systems. Adjustments to the plan shall be documented as they occur. The plan should take into consideration the time required to obtain permissions or permits from landowners or regulatory authorities. Each Transmission Owner shall have systems and procedures for documenting and tracking the planned vegetation management work and ensuring that the vegetation management work was completed according to work specifications. R3. The Transmission Owner shall report quarterly to its RRO, or the RRO's designee, sustained transmission line outages determined by the Transmission Owner to have been caused by vegetation. Draft 3 Page 4 of 7 (Proposed) Effective Date: TBA Standard FAC -003 -1 — Transmission Vegetation Management Program R3.1. Multiple sustained outages on an individual line, if caused by the same vegetation, shall be reported as one outage regardless of the actual number of outages within a 24- hour period. R3.2. The Transmission Owner is not required to report to the RRO, or the RRO's designee, certain sustained transmission line outages caused by vegetation: (1) Vegetation - related outages that result from vegetation falling into lines from outside the ROW that result from natural disasters shall not be considered reportable (examples of disasters that could create non - reportable outages include, but are not limited to, earthquakes, fires, tornados, hurricanes, landslides, wind shear, major storms as defined either by the Transmission Owner or an applicable regulatory body, ice storms, and floods), and (2) Vegetation - related outages due to human or animal activity shall not be considered reportable (examples of human or animal activity that could cause a non - reportable outage include, but are not limited to, logging, animal severing tree, vehicle contact with tree, arboricultural activities or horticultural or agricultural activities, or removal or digging of vegetation). 113.3. The outage information provided by the Transmission Owner to the RRO, or the RRO's designee, shall include at a minimum: the name of the circuit(s) outaged, the date, time and duration of the outage; a description of the cause of the outage; other pertinent comments; and any countermeasures taken by the Transmission Owner. R3.4. An outage shall be categorized as one of the following: 123.4.1. Category 1 — Grow -ins: Outages caused by vegetation growing into lines from vegetation inside and/or outside of the ROW; 123.4.2. Category 2 — Fall -ins: Outages caused by vegetation falling into lines from inside the ROW; 113.4.3. Category 3 — Fall -ins: Outages caused by vegetation falling into lines from outside the ROW. R4. The RRO shall report the outage information provided to it by Transmission Owner's, as required by Requirement 3, quarterly to NERC, as well as any actions taken by the RRO as a result of any of the reported outages. C. Measures Ml. The Transmission Owner has a documented TVMP, as identified in Requirement 1. M1.1. The Transmission Owner has documentation that the Transmission Owner performed the vegetation inspections as identified in Requirement 1.1. M1.2. The Transmission Owner has documentation that describes the clearances identified in Requirement 1.2. M1.3. The Transmission Owner has documentation that the personnel directly involved in the design and implementation of the Transmission Owner's TVMP hold the qualifications identified by the Transmission Owner as required in Requirement 1.3. M1.4. The Transmission Owner has documentation that it has identified any areas not meeting the Transmission Owner's standard for vegetation management and any mitigating measures the Transmission Owner has taken to address these deficiencies as identified in Requirement 1.4. M1.5. The Transmission Owner has a documented process for the immediate communication of imminent threats by vegetation as identified in Requirement 1.5. M2. The Transmission Owner has documentation that the Transmission Owner implemented the work plan identified in Requirement 2. Draft 3 Page 5 of 7 (Proposed) Effective Date: TBA Standard FAC -003 -1 — Transmission Vegetation Management Program M3. The Transmission Owner has documentation that it has supplied quarterly outage reports to the RRO, or the RRO's designee, as identified in Requirement 3. M4. The RRO has documentation that it provided quarterly outage reports to NERC as identified in Requirement 4. D. Compliance 1. Compliance Monitoring Process 1.1. Compliance Monitoring Responsibility RRO NERC 1.2. Compliance Monitoring Period and Reset One calendar Year 1.3. Data Retention Five Years 1.4. Additional Compliance Information The Transmission Owner shall demonstrate compliance through self - certification submitted to the compliance monitor (RRO) annually that it meets the requirements of NERC Reliability Standard FAC- 003 -1. The compliance monitor shall conduct an on- site audit every five years or more frequently as deemed appropriate by the compliance monitor to review documentation related to Reliability Standard FAC- 003 -1. Field audits of ROW vegetation conditions may be conducted if determined to be necessary by the compliance monitor. 2. Levels of Non - Compliance 2.1. Level 1: 2.1.1. The TVMP was incomplete in one of the requirements specified in any subpart of Requirement 1, or; 2.1.2. Documentation of the annual work plan, as specified in Requirement 2, was incomplete when presented to the Compliance Monitor during an on -site audit, or; 2.1.3. The RRO provided an outage report to NERC that was incomplete and did not contain the information required in Requirement 4. 2.2. Level 2: 2.2.1. The TVMP was incomplete in two of the requirements specified in any subpart of Requirement 1, or; 2.2.2. The Transmission Owner was unable to certify during its annual self - certification that it fully implemented its annual work plan, or documented deviations from, as specified in Requirement 2. 2.2.3. The Transmission Owner reported one Category 2 transmission vegetation - related outage in a calendar year. 2.3. Level 3: 2.3.1. The Transmission Owner reported one Category 1 or multiple Category 2 transmission vegetation- related outages in a calendar year, or; Draft 3 Page 6 of 7 (Proposed) Effective Date: TBA • 4 Standard FAC -003 -1 — Transmission Vegetation Management Program 2.3.2. The Transmission Owner did not maintain a set of clearances (Clearance 2), as defined in Requirement 1.2.2, to prevent flashover between vegetation and overhead ungrounded supply conductors, or; 2.3.3. The TVMP was incomplete in three of the requirements specified in any subpart of Requirement 1. 2.4. Level 4: 2.4.1. The Transmission Owner reported more than one Category 1 transmission vegetation - related outage in a calendar year, or; 2.4.2. The TVMP was incomplete in four or more of the requirements specified in any subpart of Requirement 1. E. Regional Differences None Identified. Version History Version Date Action Change Tracking Version 1 Changed "60" to "Sixty" in section A, 5.2. 01/20/06 Draft 3 Page 7 of 7 (Proposed) Effective Date: TBA • Standard FAC -003 -1 — Transmission Vegetation Management Program A. Introduction 1. Title: Transmission Vegetation Management Program 2. Number: FAC -003 -1 3. Purpose: To improve the reliability of the electric transmission systems by preventing outages from vegetation located on transmission rights -of -way (ROW) and minimizing outages from vegetation located adjacent to ROW, maintaining clearances between transmission lines and vegetation on and along transmission ROW, and reporting vegetation - related outages of the transmission systems to the respective Regional Reliability Organizations (RRO) and the North American Electric Reliability Council (NERC). 4. Applicability: 4.1. Transmission Owner. 4.2. Regional Reliability Organization. 4.3. This standard shall apply to all transmission lines operated at 200 kV and above and to any lower voltage lines designated by the RRO as critical to the reliability of the electric system in the region. 5. Effective Dates: 5.1. One calendar year from the date of adoption by the NERC Board of Trustees for Requirements 1 and 2. 5.2. Sixty calendar days from the date of adoption by the NERC Board of Trustees for Requirements 3 and 4. B. Requirements Rl. The Transmission Owner shall prepare, and keep current, a formal transmission vegetation management program (TVMP). The TVMP shall include the Transmission Owner's objectives, practices, approved procedures, and work specifications'. R1.1. The TVMP shall define a schedule for and the type (aerial, ground) of ROW vegetation inspections. This schedule should be flexible enough to adjust for changing conditions. The, inspection schedule shall be based on the anticipated growth of vegetation and any other environmental or operational factors that could impact the relationship of vegetation to the Transmission Owner's transmission lines. R1.2. The Transmission Owner, in the TVMP, shall identify and document clearances between vegetation and any overhead, ungrounded supply conductors, taking into consideration transmission line voltage, the effects of ambient temperature on conductor sag under maximum design loading, and the effects of wind velocities on conductor sway. Specifically, the Transmission Owner shall establish clearances to be achieved at the time of vegetation management work identified herein as Clearance 1, and shall also establish and maintain a set of clearances identified herein as Clearance 2 to prevent flashover between vegetation and overhead ungrounded supply conductors. R1.2.1. Clearance 1 — The Transmission Owner shall determine and document appropriate clearance distances to be achieved at the time of transmission vegetation management work based upon local conditions and the expected time frame in which the Transmission Owner plans to return for future ' ANSI A300, Tree Care Operations – Tree, Shrub, and Other Woody Plant Maintenance – Standard Practices, while not a requirement of this standard, is considered to be an industry best practice. Adopted by NERC Board of Trustees: February 7, 2006 1 of 5 Effective Date: April 7, 2006 • • Standard FAC -003 -1 — Transmission Vegetation Management Program vegetation management work. Local conditions may include, but are not limited to: operating voltage, appropriate vegetation management techniques, fire risk, reasonably anticipated tree and conductor movement, species types and growth rates, species failure characteristics, local climate and rainfall patterns, line terrain and elevation, location of the vegetation within the span, and worker approach distance requirements. Clearance 1 distances shall be greater than those defined by Clearance 2 below. R1.2.2. Clearance 2 — The Transmission Owner shall determine and document specific radial clearances to be maintained between vegetation and conductors under all rated electrical operating conditions. These minimum clearance distances are necessary to prevent flashover between vegetation and conductors and will vary due to such factors as altitude and operating voltage. These Transmission Owner- specific minimum clearance distances shall be no less than those set forth in the Institute of Electrical and Electronics Engineers (IEEE) Standard 516 -2003 (Guide for Maintenance Methods on Energized Power Lines) and as specified in its Section 4.2.2.3, Minimum Air Insulation Distances without Tools in the Air Gap. R1.2.2.1 Where transmission system transient overvoltage factors are not known, clearances shall be derived from Table 5, IEEE 516 -2003, phase -to- ground distances, with appropriate altitude correction factors applied. R1.2.2.2 Where transmission system transient overvoltage factors are known, clearances shall be derived from Table 7, IEEE 516 -2003, phase -to -phase voltages, with appropriate altitude correction factors applied. R1.3. All personnel directly involved in the design and implementation of the TVMP shall hold appropriate qualifications and training, as defined by the Transmission Owner, to perform their duties. R1.4. Each Transmission Owner shall develop mitigation measures to achieve sufficient clearances for the protection of the transmission facilities when it identifies locations on the ROW where the Transmission Owner is restricted from attaining the clearances specified in Requirement 1.2.1. R1.5. Each Transmission Owner shall establish and document a process for the immediate communication of vegetation conditions that present an imminent threat of a transmission line outage. This is so that action (temporary reduction in line rating, switching line out of service, etc.) may be taken until the threat is relieved. R2. The Transmission Owner shall create and implement an annual plan for vegetation management work to ensure the reliability of the system. The plan shall describe the methods used, such as manual clearing, mechanical clearing, herbicide treatment, or other actions. The plan should be flexible enough to adjust to changing conditions, taking into consideration anticipated growth of vegetation and all other environmental factors that may have an impact on the reliability of the transmission systems. Adjustments to the plan shall be documented as they occur. The plan should take into consideration the time required to obtain permissions or permits from landowners or regulatory authorities. Each Transmission Owner shall have systems and procedures for documenting and tracking the planned vegetation management work and ensuring that the vegetation management work was completed according to work specifications. Adopted by NERC Board of Trustees: February 7, 2006 2 of 5 Effective Date: April 7, 2006 • • Standard FAC -003 -1 — Transmission Vegetation Management Program R3. The Transmission Owner shall report quarterly to its RRO, or the RRO's designee, sustained transmission line outages determined by the Transmission Owner to have been caused by vegetation. 113.1. Multiple sustained outages on an individual line, if caused by the same vegetation, shall be reported as one outage regardless of the actual number of outages within a 24- hour period. R3.2. The Transmission Owner is not required to report to the RRO, or the RRO's designee, certain sustained transmission line outages caused by vegetation: (1) Vegetation - related outages that result from vegetation falling into lines from outside the ROW that result from natural disasters shall not be considered reportable (examples of disasters that could create non - reportable outages include, but are not limited to, earthquakes, fires, tornados, hurricanes, landslides, wind shear, major storms as defined either by the Transmission Owner or an applicable regulatory body, ice storms, and floods), and (2) Vegetation - related outages due to human or animal activity shall not be considered reportable (examples of human or animal activity that could cause a non - reportable outage include, but are not limited to, logging, animal severing tree, vehicle contact with tree, arboricultural activities or horticultural or agricultural activities, or removal or digging of vegetation). 113.3. The outage information provided by the Transmission Owner to the RRO, or the RRO's designee, shall include at a minimum: the name of the circuit(s) outaged, the date, time and duration of the outage; a description of the cause of the outage; other pertinent comments; and any countermeasures taken by the Transmission Owner. 113.4. An outage shall be categorized as one of the following: R3.4.1. Category 1 — Grow -ins: Outages caused by vegetation growing into lines from vegetation inside and/or outside of the ROW; R3.4.2. Category 2 — Fall -ins: Outages caused by vegetation falling into lines from inside the ROW; 113.4.3. Category 3 — Fall -ins: Outages caused by vegetation falling into lines from outside the ROW. R4. The RRO shall report the outage information provided to it by Transmission Owner's, as required by Requirement 3, quarterly to NERC, as well as any actions taken by the RRO as a result of any of the reported outages. C. Measures Ml. The Transmission Owner has a documented TVMP, as identified in Requirement 1. M1.1. The Transmission Owner has documentation that the Transmission Owner performed the vegetation inspections as identified in Requirement 1.1. M1.2. The Transmission Owner has documentation that describes the clearances identified in Requirement 1.2. M1.3. The Transmission Owner has documentation that the personnel directly involved in the design and implementation of the Transmission Owner's TVMP hold the qualifications identified by the Transmission Owner as required in Requirement 1.3. M1.4. The Transmission Owner has documentation that it has identified any areas not meeting the Transmission Owner's standard for vegetation management and any mitigating measures the Transmission Owner has taken to address these deficiencies as identified in Requirement 1.4. Adopted by NERC Board of Trustees: February 7, 2006 3 of 5 Effective Date: April 7, 2006 • • Standard FAC -003 -1 — Transmission Vegetation Management Program M1.5. The Transmission Owner has a documented process for the immediate communication of imminent threats by vegetation as identified in Requirement 1.5. M2. The Transmission Owner has documentation that the Transmission Owner implemented the work plan identified in Requirement 2. M3. The Transmission Owner has documentation that it has supplied quarterly outage reports to the RRO, or the RRO's designee, as identified in Requirement 3. M4. The RRO has documentation that it provided quarterly outage reports to NERC as identified in Requirement 4. D. Compliance 1. Compliance Monitoring Process 1.1. Compliance Monitoring Responsibility RRO NERC 1.2. Compliance Monitoring Period and Reset One calendar Year 1.3. Data Retention Five Years 1.4. Additional Compliance Information The Transmission Owner shall demonstrate compliance through self - certification submitted to the compliance monitor (RRO) annually that it meets the requirements of NERC Reliability Standard FAC- 003 -1. The compliance monitor shall conduct an on- site audit every five years or more frequently as deemed appropriate by the compliance monitor to review documentation related to Reliability Standard FAC- 003 -1. Field audits of ROW vegetation conditions may be conducted if determined to be necessary by the compliance monitor. 2. Levels of Non - Compliance 2.1. Level 1: 2.1.1. The TVMP was incomplete in one of the requirements specified in any subpart of Requirement 1, or; 2.1.2. Documentation of the annual work plan, as specified in Requirement 2, was incomplete when presented to the Compliance Monitor during an on -site audit, or; 2.1.3. The RRO provided an outage report to NERC that was incomplete and did not contain the information required in Requirement 4. 2.2. Level 2: 2.2.1. The TVMP was incomplete in two of the requirements specified in any subpart of Requirement 1, or; 2.2.2. The Transmission Owner was unable to certify during its annual self - certification that it fully implemented its annual work plan, or documented deviations from, as specified in Requirement 2. 2.2.3. The Transmission Owner reported one Category 2 transmission vegetation - related outage in a calendar year. Adopted by NERC Board of Trustees: February 7, 2006 Effective Date: April 7, 2006 4 of 5 • • Standard FAC -003 -1 — Transmission Vegetation Management Program 2.3. Level 3: 2.3.1. The Transmission Owner reported one Category 1 or multiple Category 2 transmission vegetation - related outages in a calendar year, or; 2.3.2. The Transmission Owner did not maintain a set of clearances (Clearance 2), as defined in Requirement 1.2.2, to prevent flashover between vegetation and overhead ungrounded supply conductors, or; 2.3.3. The TVMP was incomplete in three of the requirements specified in any subpart of Requirement 1. 2.4. Level 4: 2.4.1. The Transmission Owner reported more than one Category 1 transmission vegetation - related outage in a calendar year, or; 2.4.2. The TVMP was incomplete in four or more of the requirements specified in any subpart of Requirement 1. E. Regional Differences None Identified. Version History Version Date Action Change Tracking Version 1 TBA 1. Added "Standard Development 01/20/06 Roadmap." 2. Changed "60" to "Sixty" in section A, 5.2. 3. Added "Proposed Effective Date: April 7, 2006" to footer. 4. Added "Draft 3: November 17, 2005" to footer. Adopted by NERC Board of Trustees: February 7, 2006 6 of 5 Effective Date: April 7, 2006 • • UTILITY VEGETATION MANAGEMENT AND BULK ELECTRIC RELIABILITY REPORT FROM THE FEDERAL ENERGY REGULATORY COMMISSION SEPTEMBER 7, 2004 • • Executive Summary Electric transmission owners and operators conduct vegetation management to prevent physical contact between transmission lines and nearby vegetation that could cause a transmission line to fail. On August 14, 2003, an electric power blackout affected large portions of the Northeast and Midwest United States and Ontario, Canada. President George W. Bush and Prime Minister Jean Chretien established a joint U.S. - Canada Power System Outage Task Force (Task Force) to investigate the causes of the blackout and how to reduce the possibility of future outages. On April 5, 2004, the Task Force issued a Final Blackout Report1 stating that one of the four primary causes of the blackout was inadequate vegetation management (tree pruning and removal). In response to the Final Blackout Report, the Federal Energy Regulatory Commission (Commission) directed all designated transmission owners to file reports with the Commission by June 17, 2004, explaining their vegetation management practices for designated transmission facilities and rights- of -way.2 The Commission staff worked with the leadership of the National Association of Regulatory Utility Commissioners' (NARUC) ad -hoc Committee on Critical Infrastructure to analyze these reports to look for significant patterns and potential problems in the vegetation management practices of the electric industry. This report to Congress summarizes the Commission's findings and recommendations. In this report, the Commission also recommends that Congress enact legislation providing for mandatory, enforceable reliability rules. Key Observations The transmission owners were asked to report on the results of their most recent transmission line vegetation management inspections, necessary remedial actions identified, and whether such actions had been completed before the summer 2004 peak 1 U.S. -Canada Power System Outage Task Force, Final Report on the August 14th Blackout in the United States and Canada: Causes and Recommendations (April 2004) (Final Blackout Report). 2 Order Requiring Reporting on Vegetation Management Practices Related to Designated Transmission Facilities, 107 FERC 1161,053 (2004) (Vegetation Management Order). Designated transmission facilities" are defined, for the purposes of the Vegetation Management Order only, as transmission lines with a rating of 230 kV or higher as well as tie -line interconnection facilities between control areas or balancing authority areas (regardless of kV rating) and "critical" lines as designated by the regional reliability council. See NERC, August 14, 2003 Blackout: NERC Actions to Prevent and Mitigate the Impacts of Future Cascading Blackouts at 9 n.3 (Feb. 10, 2004). • • load season. Review of the vegetation management filings found that it appears transmission owners and operators have performed extensive vegetation management along the nation's high - voltage transmission network, which should produce better grid reliability during the summer. However, there is a wide range of vegetation management practices and procedures among the reporting transmission owners. There is very little uniformity in regard to right -of -way width,3 vertical line clearance,4 inspection frequency,5 and vegetation management guidelines6 used. The lack of uniformity may be understandable in part, as transmission owners must design their vegetation management practices based on factors such as the demands of the terrain, location, climate, vegetation species, and local laws and regulations. The Commission recognizes that, while the data filed in response to the Vegetation Management Order reveals each transmission owner's practice, it does not directly address how effective the practice has been in limiting preventable transmission line outages. The Commission did not ask for such data in the April request, because similar data are now being reported to the Western Electricity Coordinating Council and to the North American Electric Reliability Council (NERC). Such a review is beyond the scope of this report. Transmission owners report that they are not able to acquire all necessary permits to maintain their rights -of -way from various federal and state agencies. However, this problem could be alleviated, at least in part, if the acquisition of these permits is made a higher priority on the part of transmission owners. For instance, transmission owners could allow additional lead time to acquire many needed permits. The agencies responsible for issuing permits, however, should ensure that they have clear rules and procedures for issuing permits in a timely manner. With respect to any jurisdiction issues that may arise involving vegetation management, it is important that state and federal regulators continue to coordinate so that jurisdictional considerations do not impede effective vegetation management. 3 A right -of -way is a segment of land used for the route of a transmission line. A right -of -way should be devoid of vegetation that can interfere with a transmission line. The right -of -way width is the distance between the outer bounds of a right -of -way. a The vertical distance between a tree or vegetation and an electric transmission wire. 5 The time between complete inspections of a utility's transmission system, e.g., semiannual, annual, etc. 6 The guidelines that utilities report they adhere to in regards to the management of vegetation along transmission lines. 2 • The Commission believes that better coordination among federal agencies and between the federal and state governments to develop clear, consistent policies and procedures for timely and effective vegetation management by transmission owners could help to alleviate many real and perceived obstacles to proper vegetation management. The transmission owners reported that vegetation management approvals on federally managed rights -of -way are particularly problematic in the Western United States. The Council on Environmental Quality (CEQ) coordinates federal environmental efforts and helps resolve inter- agency differences over environmental issues. The Commission believes federal agencies and the CEQ should work together on vegetation management on federal rights -of -way. In addition, the CEQ could facilitate coordination with Native American tribes for vegetation management on Native American tribal lands. We understand that vegetation management practices affect the environment and look forward to working with other agencies to coordinate efforts to assure that neither the environmental quality of federal lands nor regional electric reliability are put at risk. Summary of Recommendations 1) The United States Congress should enact legislation to make reliability standards mandatory and enforceable under federal oversight. 2) Effective transmission vegetation management requires clear, unambiguous, enforceable standards that adequately describe actions necessary by each responsible party. 3) With respect to any jurisdiction issues that may arise involving vegetation management, it is important that state and federal regulators continue to coordinate so that jurisdictional considerations do not impede effective vegetation management. 4) Federal and state regulators should allow reasonable recovery for the costs of vegetation management expenses. 5) While permitting and environmental requirements properly protect public lands, the procedures implementing those protections may be inconsistent and time - consuming and have the potential to significantly hinder transmission vegetation management. The Commission should work with the CEQ and land management agencies to better coordinate these requirements. 6) Federal, state and local land managers should develop "rush" procedures and emergency exemptions to allow utilities to correct "danger" trees that threaten transmission lines, from both on and off documented rights -of -way. 7 A danger tree is a tree that is dead or dying and has the potential to fall into a 3 • • 7) Five -year vegetation management cycles should be shortened, and the Commission and states should look at the cost - effectiveness of more aggressive vegetation management practices. 8) Transmission owners should fully exercise their easement rights for vegetation management and better anticipate and manage the permitting process for scheduled vegetation management. 9) Variances in vegetation management practices may be resolved in the NERC vegetation management standard development process; if they are not, the Commission may seek to convene the industry, states and other stakeholders to address the remaining issues. 10) State regulators and the utility industry should work through NARUC, the National Conference of State Legislators, and other organizations to help state and local officials better understand and address transmission vegetation management. Introduction On August 14, 2003, an electric power blackout occurred over large portions of the Northeast and Midwest United States and Ontario, Canada. The blackout lasted up to two days in some areas of the United States and longer in some areas of Canada. It affected an area with over 50 million people and 61,800 megawatts of electric load. In the wake of the blackout, a joint U.S.- Canada Task Force (Task Force) undertook a study of the causes of that blackout and possible solutions to avoid future such blackouts. The Task Force's Final Report was issued on April 5, 2004. The Task Force identified FirstEnergy Corporation's (FirstEnergy) failure to adequately prune trees and manage vegetation in its transmission rights -of -way as one of the four primary causes of the August 14, 2003 blackout.8 The blackout investigation explained that, during the hour before the cascading blackout occurred, three FirstEnergy 345 kV transmission lines failed as a result of contact between the lines and overgrown vegetation that encroached into the required clearance zone for the lines.9 It stated that "because the trees were so tall ... each of these [three] lines faulted under system conditions well within specified operating parameters. "10 right -of -way close to a line. 8 Final Blackout Report at 20. 9 Id. at 57 -67. to Id. at 58. 4 • • The Final Blackout Report also compared the August 2003 blackout with seven previous major outages and concluded that conductor contact with trees was a common factor among the outages." The Task Force emphasized that vegetation management is critical, and that many outages can be prevented by managing vegetation before it becomes a problem.1 It also noted that investigation reports from previous major outages recommended paying special attention to the condition of vegetation on rights - of -way and the need for preventative maintenance in this area. In March 2004, the Commission made available to the public a 128 -page vegetation management report, prepared to support the blackout investigation.13 The report details problems with vegetation management relating to the August 2003 blackout, and the impact of vegetation management on electric reliability. The report concludes that the August 2003 blackout likely would not have occurred had the rights - of -way been maintained for three 345 kV transmission lines that tripped due to tree -line contacts.14 It also concludes that utilities responsible for the right -of -way maintenance had in place vegetation management programs that were in line with current industry norms. Further, it concludes that current industry "standards" are inadequate and must be improved. The CNUC Final Vegetation Report recommends specific practices that would reduce the likelihood of tree and power line contacts and provides recommendations for the oversight and enforcement of utility vegetation management activities. On April 19, 2004, the Commission issued the Vegetation Management Order requiring all entities that own, control or operate designated electric transmission facilities in the lower 48 states to provide information on their vegetation management practices. This order was issued pursuant to section 311 of the Federal Power Act, 16 U.S.C. § 825j (2000) which authorizes the Commission to conduct investigations in order to secure information necessary or appropriate as a basis for recommending legislation. The Commission ordered that designated transmission owners describe in detail the practices and standards that the transmission owner uses for control of vegetation near designated transmission facilities, and indicate the source of any standard utilized (e.g. state law or regulation, historical practice). In addition, transmission owners were asked 11/d. at 107. 12Id.at59. 13 CN Utility Consulting, Utility Vegetation Management Final Report, (March 2004) (CNUC Final Vegetation Report). The CNUC Final Vegetation Report is available on the Internet at www. ferc. gov /cust- protect/moi/blackout.asp. 14 Id. at 26 -27. 5 • • to describe the clearance assumptions or definition used for the appropriate distance between vegetation and the facilities, how often the transmission provider inspects that facility for vegetation management purposes, whether identified remediation has been completed as of June 14, 2004, and any factors that the respondent believes prevents, or unduly delays, the performance of adequate vegetation management.15 This report analyzes the information gathered pursuant to the Vegetation Management Order, provides relevant additional information regarding the current status of vegetation management practices, and offers a recommendation for Congressional consideration. Review and Analysis Method The Commission received 161 responses from transmission owners.16 On June 21 -22, 2004, Commission staff, along with three state commissioners, Connie Hughes of New Jersey, Don Mason of Ohio, and Judith Ripley of Indiana, representing the leadership of the NARUC ad -hoc Committee on Critical Infrastructure, performed an initial review of the vegetation management responses.17 This initial two -day review was intended to identify any immediate issues that could potentially impact electric grid reliability requiring rapid follow up by state or federal regulators. In addition, it looked for progress made since the blackout of the previous year, fact patterns suggesting additional inquiry is required, and a general overview of current vegetation management practices. The initial review was followed up by a more intensive Commission staff data analysis. This analysis included the creation of a database that tracked: • all respondents' right -of -way width maintained in feet by voltage, • vertical line clearance in feet by voltage, • ground and aerial inspection frequency, • vegetation management cycle,18 and • vegetation management guidelines utilized, if any. 15 Vegetation Management Order at P 12. 16 Some respondents provided responses on behalf of multiple operating companies or multiple transmission owners. 17 Edison Electric Institute (EEI) prepared templates for its members to use in filing the requested data. Many EEI members used these templates. The templates made it easier for Commission staff to review the filings. 18 The period of time required for a utility to perform maintenance including the pruning of all vegetation and the removal of all vegetation of concern on its entire transmission system. 6 • • Commission staff reviewed the data in the five categories above and looked for patterns in vegetation management practices.19 Findings The majority of respondents have completed necessary vegetation management remediation measures identified during the most recent inspection of their transmission lines. While this does not guarantee that there will not be adverse impact to grid reliability caused by vegetation interfering with transmission lines, it is a positive indication of reduced risk to reliability. However, 29 percent of respondents identified some line vegetation management remediation that was not completed by the June 17 filing date and may not be performed this summer.20 A list of these respondents is provided in Attachment A. The results suggest that a significant amount of the remediation occurred between April 19, 2004 and June 14, 2004. Utility vegetation management practices vary significantly. While some variation is expected because vegetation management practices are affected by climate, terrain, vegetation species, local laws, and regulations, other variations are unexplained. Below is a discussion of reported data on right -of -way width, vertical clearances, inspection frequency, vegetation management cycles, and vegetation management guidelines followed. Some of these variations may be resolved in the NERC vegetation management standard development process;21 if they are not, the Commission may seek to convene the industry, states and other stakeholders to address the remaining issues. 1. Right -of -way Width 19 In their filings, certain respondents asked for and were granted protection regarding specific transmission line information under the Commission's Critical Energy Infrastructure Information (CEII) policy. CEII is information concerning proposed or existing critical infrastructure (physical or virtual) that relates to the production, generation, transmission or distribution of energy. While this report does not disclose any specific CEII data, the Commission's conclusions reflect its review of such data. 20 In some instances, the transmission owner /operator reported that remediation before the summer was not needed and would be completed as part of the regular vegetation management cycles later in the year. In other instances, the respondent states that there is no immediate threat to the line. Some stated that the work would be completed shortly after June 17 or as soon as possible. In at least one case, the required work was pending reaching agreement with a landowner. 21 NERC recently initiated a vegetation management standard development process. See ftp://www.nerc.com/ pub /sys /al'l_upol/docs/bot/Agenda- Items- 0604/Item 12e.pdf. 7 • • Right -of -way widths vary significantly among the reporting transmission owners. Generally, right -of -way width increases as line voltage increases. Higher voltage lines require wider rights -of -way because greater separation is needed between conductors. Wider right -of -way widths are also necessary to accommodate multiple lines and in some cases more than one tower. Since right -of -way width depends on many factors, and since some respondents provided ranges that depend on such factors as the number of circuits on a right -of -way, no pattern was identified from the data on the range of right -of -way widths. Table 1 shows the range of responses by voltage class. Table 1. Right -of -Way Width Right -of -Way Width 500 kV 345 kV 230 kV Less than 230 kV Minimum Width (ft) # of Companies Minimum Width (ft) # of Companies Minimum Width (ft) # of Companies Minimum Width (ft) # of Companies Less than 125 4 Less than 75 6 Less than 75 40 Less than 50 51 126 -175 21 76 -125 36 76 -125 36 51 -125 41 176 > 13 126 > 30 126 > 30 126 > 7 In general, if a utility has a wider right -of -way, well documented right -of -way easement rights, and exercises those rights fully, it will be more successful in avoiding vegetation -line contact than a utility that maintains narrower rights -of -way. A narrow right -of -way increases the risk of contact with vegetation that is outside of the right -of- way and adjacent to the transmission line. Expert commentary included in the CNUC Final Vegetation Report stated, "[m]ost tree /power line contacts occur when trees fall onto lines from outside the rights -of -ways or corridors. Many utilities are slow to act to address this issue due to the perception of increased costs and the pressure from landowners etc. to leave trees standing. "22 2. Inspection Frequency Vegetation management inspections are performed to inspect the status of vegetation and the rights -of -way surrounding electric transmission facilities. During these inspections, vegetation of concern is noted and scheduled for remediation. Typically, a utility will utilize a combination of aerial and ground inspections. Ground inspections are performed by walking or driving the length of transmission lines to inspect the condition of vegetation. While slow, ground inspections may be more effective because they enable an inspector to more thoroughly view vegetation conditions and the relationship between vegetation and the wire. Aerial inspections are performed using aircraft (a helicopter or a small plane flying at low altitude) to visually inspect the 22 CNUC Final Vegetation Report at 115. 8 • • condition of vegetation. Given the greater distance from the vegetation and the speed of aerial inspection, it is considered to be less reliable and thorough than ground inspection. Annual, semi - annual, or more frequent aerial patrols are part of the transmission inspection practice of 105 utilities, twenty -five of which conduct aerial inspections more frequently than twice a year. Table 2 summarizes the responses. Table 2. Aerial Inspection Frequency Aerial Inspection Frequency # of Companies More than twice a year 25 Semi - annual 34 Annual 46 Biennial 6 Every 3 years 1 > than 3 Years 3 As Needed 8 Did Not Report 38 Most transmission owners use aerial patrols to identify areas that need remediation or areas that will need remediation soon. Aerial inspections are followed by additional ground inspection or remediation. Over 100 respondents indicate that they conduct annual or more frequent ground inspections of their entire system. Ground patrols are more effective in identifying vegetation - related problems.23 Table 3 summarizes the responses. 23 CNUC Final Vegetation Report at 49. 9 Table 3. Ground Inspection Frequency Ground Inspection # of Companies Frequency More than twice a year 7 Semi - annual 22 Annual 76 Biennial 6 Every 3 years 6 > than 3 Years 25 As Needed 12 Did Not Report 7 As with right -of -way width, patrol frequency and method varies significantly among reporting utilities. This could be due to the variation in the number of transmission circuit miles owned or operated by the utility, terrain, and vegetation characteristics. 3. Vertical Clearance Vertical clearance is the distance between a wire and the vegetation directly below it.24 The minimum vertical clearance requirement increases by line voltage (although some transmission owners reported the same vertical clearance for all voltage classes). The maintenance of sufficient vertical distance between the conductor and vegetation is essential because direct physical contact is not necessary for a line outage to occur. An electric arc can occur between a part of a tree and a nearby high- voltage conductor without sufficient clearance.25 These electric arcs can cause fires and line outages. Vegetation management practices should maintain a minimum vertical clearance between a line and a tree. The pruning should create clearances with a healthy safety margin beyond the minimum required clearance that will last until the next scheduled pruning or treatment. Table 4 shows vertical clearances used by reporting utilities. 24 Vegetation can interfere with power lines from below, sides, and above and appropriate clearance must be maintained all around the wire. This section discusses vertical line clearance as an example of the variation among utilities in maintaining line clearances. 25 In effect, electricity on a transmission wire can "jump" a very short distance from the wire to tree limbs without direct contact, creating a short circuit that can lead to a line outage. 10 Table 4. Vertical Clearances Reported Vertical Clearance Table 500 kV 345 kV 230 kV Less than 230 kV Clearance (ft) # of Companies Clearance (ft) # of Companies Clearance (ft) # of Companies Clearance (ft) # of Companies 0 -15 11 0 -15 17 0 -10 23 0 -10 16 16 -20 11 16 -20 17 11 -15 17 11 -15 20 21 -25 9 21 -25 12 16 -20 24 16 -20 14 26> 8 26 > 14 21 -25 16 21 -25 3 26> 13 26> 5 There is no apparent rationale for the wide variance in vertical clearance requirements.26 The current industry effort through NERC to develop a vegetation management standard should resolve this issue. 4. Vegetation Management Cycle A vegetation management cycle is loosely defined as the time it takes to complete the pruning and removal of trees or other vegetation on a utility's entire transmission system. In most cases, a utility prunes or treats a portion of its total circuit -miles of right - of -way in each year; once the circuit is completed, the company starts the cycle over. The Vegetation Management Order did not formally request this information, but the CNUC Final Vegetation Report found that a five -year cycle is the industry norm. Furthermore, the report found that the five -year cycle is insufficient to maintain reliability. Of the 70 respondents that volunteered their vegetation management cycles, many indicate that they prune and remove vegetation along their lines within a five -year or longer interval.27 Table 5 summarizes the responses. 26 There could have been varying interpretations of the reporting requirement (e.g., clearance achieved at the time of pruning vs. minimum clearance maintained). However, the EEI templates used by a large number of respondents instructed that "minimum clearance maintained between conductor and vegetation" be reported. 27 A five -year cycle is consistent with the industry practice; however, common or average industry practices need improvement. Final Blackout Report at 59. 11 • • Table 5. Pruning Cycle Pruning Cycle # of Frequency Companies 0 -2 years 11 3 -4 years 35 5 or More years 24 In the future, the Commission and the industry should work to identify the correlation between vegetation management practices and actual vegetation- caused transmission line outages. When managing vegetation, 93 companies employ herbicides to limit vegetation growth; others use mechanical techniques to cut vegetation on rights -of -way; and some use a combination of both.28 5. Current Vegetation Management Guidelines Establishing clear, unambiguous standards pertaining to maintenance of safe clearances of transmission lines from obstructions in rights -of -way was one of the recommendations of the Final Blackout Report.29 The vast majority of transmission owners report that they follow the National Electrical Safety Code (NESC) rules or American National Standards Institute (ANSI) guidelines, or both when managing vegetation around transmission lines. The NESC deals with electric safety rules, including transmission wire clearance standards, while the applicable ANSI code deals with the practice of pruning and removal of vegetation. However, these rules and guidelines are not specific with regard to clearances between transmission lines and vegetation and are subject to interpretation. Nor do these rules provide a performance target for keeping vegetation from conflicting with transmission lines. Furthermore, these standards are not enforceable upon transmission owners, but have been adopted by NESC and ANSI as guidelines for appropriate practice. • 104 utilities indicate that they adhere to NESC standards for transmission system maintenance. • 92 of these specifically adhere to NESC Rule 218, which only provides that 28 Mechanical and chemical techniques are not mutually exclusive in general. Rather, mechanically clearing, e.g. with a bushhog, might take place followed by treatment with herbicide to retard regrowth. 29 Final Blackout Report at 154. 12 • • trees that may interfere with conductors should be trimmed or removed. NESC Rule 218 does not prescribe clearances. • 12 reported that they specifically follow NESC Rule 232, 233 or 234 which prescribes clearances of wires from ground, structures, and other installations. • 34 respondents follow ANSI A300, which deals with proper tree pruning techniques to maintain the health of the tree, and does not contain any clearance requirements. • ANSI Z133, used by 22 transmission owners, provides guidelines for utilities related to worker and public safety during tree pruning and removal operations. • A large number of respondents adhere to NESC standards in conjunction with ANSI standards such as A300. • 96 transmission owners report that they use internally - developed, state, or other guidelines. Respondents did not explain why they follow a particular standard. As stated earlier, NERC is in the process of developing a vegetation management standard that may resolve the current lack of a clear, unambiguous standard. Good Practices The CNUC Final Vegetation Report identified a number of good utility vegetation management practices. Among these good practices for existing rights -of -way are: • Application of wire zone — border zone concepts (described below) • Proper consideration of line sag and sway • Frequent field inspection of vegetation conditions • Comprehensive public education programs In reviewing the filings, Commission identified a number of utilities that report practices consistent with the best practices identified in the CNUC Final Vegetation Report. Some examples follow. One good practice relates to customer education. For example, some utilities have public outreach programs that educate the public about tree types and line clearances so that citizens will have the knowledge to report vegetation that is dangerous to transmission wires. Several transmission owners employ a wire zone — border zone approach which is both environmentally friendly and effective in ensuring reliability. This method involves creating a low- growing vegetation environment directly under transmission lines, which physically prevents dangerous vegetation from encroaching into energized transmission facilities. The CNUC Final Vegetation Report stated that the wire zone - border zone has 13 • • "been proven to be effective in reducing and /or eliminating outages related to vegetation on transmission ROW [rights of way]." ° The wire zone - border zone concept is depicted in the graphic below. Bramble and Byrnes Wire Zone - Border Zone (From Ya%ner, Bramtte and Byrne s, 2000 Several companies have taken measures to improve vegetation management - related reliability. Certain utilities, for example, conduct frequent ground and aerial patrols, as well as an inspection of all of its power lines after every major storm. Reported Obstacles to Effective Vegetation Management In trying to understand the state of the industry's vegetation management programs, the Vegetation Management Order sought information on factors that the utilities believe prevent or unduly delay their performance of adequate vegetation management. Sixty -six utilities report that their efforts to properly maintain their transmission lines are impeded by a variety of federal and state regulations that legally or practically prevent them from performing effective vegetation management. While such ordinances can be problematic and hinder the vegetation management process, proper planning and foresight on the part of the utilities, including allowances for additional lead time, would likely reduce the threat to vegetation management caused by some ordinances. 30 CNUC Final Vegetation Report at 21. 14 List of Reported Obstacles Reported Obstacles Responses U.S. Forest Service 22 U.S. Fish and Wildlife Service 12 National Park Service 6 Departments of Transportation 6 Other Federal /State/Local Governments 35 Private Landowners 20 Other 10 No transmission owners complained of the fmancial costs of vegetation management. In many instances, a situation may arise in which a transmission owner is not able to plan for vegetation management. For example, trees can become hazardous to a line suddenly, as when a tree is dead or dying and has the potential to fall into a right -of -way and impact a line. These are a risk to reliability as long as the situation is not corrected, and so must be dealt with on a priority basis. Many transmission owners reported that the permitting processes can impede action necessary to properly manage situations such as this. The conflicting goals and requirements for environmental protection and electric reliability create practical problems for vegetation management. Transmission owners cite federal regulations and their enforcement programs most frequently as impeding their ability to properly manage the vegetation within transmission line rights -of -way. 31 Twenty -two transmission owners cited U.S. Forest Service (Forest Service) restrictions on transmission owners across the country. They state that the Forest Service requires impact studies on wildlife and habitat impacts, requires environmental impact assessments, and limits the use of access roads to transmission rights -of -way and has inconsistent permitting procedures across the National Forests. In addition, twelve utilities claim that the U.S. Fish and Wildlife Service restricts the times at which trees can be pruned and limits herbicide use in order to maintain endangered species habitats. If 31 Some of the land management agencies have already begun streamlining their permitting processes. For example, the Forest Service began overhauling its permitting and environmental review process over a year ago. These changes should reduce the impact of permitting on vegetation management. 15 • • herbicide use is limited, many manually or mechanically removed trees can re- sprout and quickly grow back into power lines. Utilities also report that the various state Departments of Transportation had restricted tree pruning and removal in the name of "beautification" efforts. Otter Tail Power reports that the U.S. Department of Transportation, the U.S. Fish and Wildlife Service, and the Department of Natural Resources have repeatedly planted trees in its rights -of -way. Several companies stated that state government organizations had taken action that they believed hindered their reliability programs as well. For instance, PacifiCorp reports that the Utah Department of Transportation had planted trees directly under several of its 345 kV transmission lines and would not allow them to be pruned. The New York State Department of Environmental Conservation requires transmission owners to file "Temporary Revocable Permits" that take up to two years to process for transmission owners to get access to trees that need to be managed. Respondents also claim that a variety of local regulations and property owners prevent effective vegetation management. One of the most frequent claims is local and private entities limit the use of herbicides and the removal of trees. Some local park restrictions hinder trucks from accessing power lines. Native American tribes are sovereign and can restrict transmission owners in numerous ways when transmission rights -of -way pass through tribal land. For many utilities, attempting to manage numerous local and private restrictions can be extremely burdensome and can result in failure to conduct effective vegetation management. For example, the outage that occurred on Cinergy's 345 kV Columbus — Bedford line on August 14, 2003 was due to a property owner's refusal to allow Cinergy to complete the required work.32 Cinergy had documented rights at the location but work was halted due to a court- granted temporary injunction obtained by the property owner. Need For Legislation Ineffective vegetation management was a major cause of the August 14, 2003 blackout and a contributing factor to other large -scale blackouts. The U.S.- Canada Task Force found that clear, unambiguous, and enforceable standards are needed to reduce the potential for reoccurrence of vegetation related transmission line outages and recommended that NERC, in cooperation with the industry and the appropriate governmental agencies, develop such a standard.33 The Commission's review of the responses submitted confirms a lack of common standards and significant variations among utilities in their vegetation management practices. 32 CNUC Final Vegetation Report at 36. 33 Final Blackout Report at 154. 16 • NERC recently initiated a vegetation management standard development process. The Commission supports NERC's initiative to develop a clear, unambiguous vegetation management standard. However, adherence to NERC standards will be voluntary unless Congress enacts legislation with a clear federal framework for mandating development and enforcement of this and other reliability rules. Recommendations The following recommendations are based on the information received in response to the Vegetation Management Order. The Commission has also drawn from the Blackout Report and the CNUC Final Vegetation Report. These recommendations were developed in collaborative discussions between the Commission staff and the state commissioners who participated in the initial review. 1) The United States Congress should enact legislation to establish an Electric Reliability Organization and make its standards mandatory and enforceable, under federal oversight. Under such legislation, if the Commission were to approve a NERC standard, then it would be mandatory and enforceable for all transmission owners and operators. Mandatory, enforceable standards will result in greater compliance and, therefore reduce the likelihood of individual transmission line outages due to tree contacts, electric arcing, and fires, and thus improve local and regional grid reliability. 2) Effective transmission vegetation management requires clear, unambiguous, enforceable standards that adequately describe the actions necessary by each responsible party. The NERC standard now being developed should serve this purpose. We recognize that the details of such standards must respect differing vegetative, climate, terrain, and other considerations, and thus may need to balance between results required and detailed prescriptions for how to manage vegetation, so it will be challenging to develop a clear, effective standard. But it must be done, and done as quickly as possible to assure that the nation's customers and economy do not remain at risk to this known reliability threat. 3) With respect to any jurisdiction issues that may arise involving vegetation management, it is important that state and federal regulators continue to coordinate so that jurisdictional considerations do not impede effective vegetation management. 4) As noted above, no reporting utility suggests that lack of financial resources or recovery of vegetation management expenses is an obstacle to the achievement of vegetation management goals. Nevertheless, both federal and state regulators should be sensitive to requests for rate adjustments in order to recover reasonable reliability and security related expenses such as those for vegetation management.34 34 See, e.g., Policy Statement on Matters Related to Bulk System Reliability, 107 17 • • 5) The Commission should work with the CEQ and the federal land management agencies to streamline and better coordinate permitting and environmental requirements to facilitate better vegetation management without compromising environmental quality. While it is entirely appropriate that federal and state land managers protect the lands for which they have responsibility, the costs and consequences of vegetation- caused outages or blackouts are so high that agencies should reexamine these processes and requirements to see whether they need to be reformed. The Commission commits to work with the CEQ and other federal land management agencies on such an effort. Additionally, the CEQ could facilitate coordination with Native American Tribes for vegetation management on Native American tribal lands. 6) Outages are often caused by trees that become hazardous to a line, as when a tree is dead or dying and has the potential to fall into a right -of -way and impact a line. These are a risk to reliability as long as the situation is not corrected, and so must be dealt with on a priority basis. State, local and federal land managers should recognize the importance of this situation and should develop priority or rush procedures to allow the utility to take prompt corrective action to mitigate these "danger" trees. 7) Since numerous recent major blackouts have been caused by tree contacts with transmission lines, and the August 14, 2003 blackout was caused by trees that were managed on a five -year vegetation management cycle, the CNUC Final Vegetation Report concluded that a five -year cycle, while the industry norm, is not effective nor adequate for assuring transmission reliability across much of North America. For that reason, a shorter cycle should be used. While this and other enhanced vegetation management requirements suggested herein may increase utility costs, given the substantial and perhaps growing costs of reliability failures of the modern grid, the Commission and the states should encourage cost - benefit studies to examine the relative costs and benefits of current and more aggressive vegetation management practices. 8) Transmission owners should work to remove the obstacles to effective vegetation management along transmission rights -of -way. This should include, at minimum: • Whenever possible, renegotiation of easement provisions where they do not grant adequate clearance and vegetation management rights. • Full exercise of all existing easement provisions and rights to assure adequate tree - pruning and clearing. • Where landowners or land managers have established lengthy permitting requirements or time - limited vegetation management operational windows, planning ahead to assure that the transmission owner or operator secures the FERC ¶ 61,052 at P 27 -28 (2004). 18 • • needed permissions in a timely and predictable fashion. 9) Variances in vegetation management practices may be resolved in the North American Electric Reliability Council (NERC) vegetation management standard development process; if they are not, the Commission may seek to convene the industry, states and other stakeholders to address the remaining. 10) State regulators and the utility industry should approach NARUC, National Conference of State Legislators, and similar organizations to develop model guidelines and educational materials that can be used to help state and local officials understand the importance of this issue and how to manage it more effectively, through measures such as tree - pruning and tree- planting ordinances. If state legislation or changed agency rules are needed, utilities and state utility regulators should take the lead within each state to initiate the communications and cooperative discussions required. The Commission would support this effort, if requested. 19 Attachment A Companies that did not perform all identified vegetation management remediation by the June 14, 2004 reporting date • American Transmission Co. • Aquila, Inc. • Austin Energy • Basin Electric Power Cooperative • Black Hills Power, Inc. • Carolina Power and Light Co. • Central Hudson Gas and Electric Corp. • Central Louisiana Electric Company, Inc. • City of Tallahassee Electric Utility • Consolidated Edison Company of New York, Inc. • Dairyland Power Cooperative • Entergy Corp. • Georgia Transmission Corp. • Indiana- Kentucky Electric Corporation • International Transmission Co. • Lakeland Electric • Louisville Gas & Electric Co. • Lower Colorado River Authority Transmission Services Corp. • Montana - Dakota Utilities Co. • Municipal Electric Authority of Georgia • Nebraska Public Power District • New York Power Authority • NorthWestern Energy • Nstar Electric and Gas Corp. • Ohio Valley Electric Corp. • Oklahoma Gas & Electric Co. • PacifiCorp • PPL Electric Utility Corp. • Public Utility District No.1 of Chelan County • Puget Sound Energy, Inc. • Rappahannock Electric Cooperative • Santee Cooper Power • Seattle City Light • Sierra Pacific Power Co. • South Carolina Gas & Electric Co. • South Texas Electric Cooperative, Inc. • Texas Municipal Power Agency • Tucson Electric Power Co. • TXU Electric Delivery • Western Area Power Administration • Xcel Energy In some instances, the transmission owner /operator reported that remediation before the summer was not needed and would be completed as part of the regular vegetation management cycles later in the year. In other instances, the respondent states that there is no immediate threat to the line. Some stated that the work would be completed shortly after June 17 or as soon as possible. In at least one case, the required work was pending reaching agreement with a landowner. On August 26, 2004, Dairyland Power Cooperative filed an update with the Commission stating that all remediation has been completed. 1 Attachment B • • Primary Contributors LaChelle Brooks Saeed Farrokhpay Connie Hughes, Commissioner, New Jersey Board of Public Utilities Don Mason, Commissioner, Public Utilities Commission of Ohio Paul Massey Judith Ripley, Commissioner, Indiana Utility Regulatory Commission Alison Silverstein Christy Walsh Additional Staff Support Charles Bayless Jonathan First Adam Hyde Daniel John William Longenecker Gary Nakarado Robert Novembri, Partner, CN Utility Consulting, Inc. Cynthia Pointer Christian Thoroughgood r c.o� -(-)k PUGET SOUND ENERGY March 21, 2008 To: City of Tukwila From: Puget Sound Energy / ArborMetrics Solutions, Inc. / Blue Heron Services, Inc. Contact: Cate Burnett / ArborMetrics Solutions, Inc. (206)718 -8216 Contact: Kim Peterson / Blue Heron Services, Inc. (360) 793 -7767 PSE VEGETATION MANAGEMENT - INTERURBAN TRAIL PROJECT PROPOSAL PSE and associated contractors and consultants are submitting this outline of proposed work as requested at the February 14th 2008 meeting. PROPOSED VEGETATION REMOVAL Tree maintenance and vegetation control will primarily consist of girdling targeted species (chain saw cut around the girth of the standing tree); lowering of canopy (cutting and dropping limbs) if necessary for safety and finally applying a state approved aquatic herbicide (details attached.) Trees will be left standing in place unless they pose a threat to users of adjacent public rights of way or railroads. By eliminating the need for brush removal at the time of maintenance work, damage to the natural habitat and resources in the area of maintenance will be kept to a minimum. In addition, allowing trees to remain standing will provide additional and changing habitat values within the wetland and buffer areas. Hand cutting and removal, as well as limited clearing, will lessen all soil impacts; no soil impacts are expected other then slight disturbance along pathways used for access This maintenance procedure does include the application of herbicides as a final component of the process. Herbicide application will be thorough low - pressure hand application of herbicide to each tree which is cut or girdled. All herbicides will meet requirements of the State of Washington, King County and any City local regulations. Additional herbicide information is attached to this outline of proposed work. The work referenced in this outline is an extension of the continual on -going maintenance which is conducted by PSE within its easements. This specific control work will continue into the future, as necessary, with the goal of meeting the Federal mandates for the continued safe operation of the 230kV transmission lines. 1 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK RErFI' /FD MAP 9 711f8I DEVELUn'... PSE VEGETATION MANAGEMENT — FERC AND NERC MANDATES The work defined in this outline will be conducted in conformance with the recent updated FERC/NERC rules. Federal requirements (FERC and NERC regulations) mandate that all owners of 230kV transmission lines create protocols for management which will assure the minimum security defined in the recent rulings. HISTORY AND UPDATE: This recent. more stringent. FERC/NERC regulations require more specific maintenance procedures and protocols for the regular maintenance work conducted. These requirement include clear and concise 5 definitions for trees species which will not be allowed within the transmission line right of ways and ' 15t be removed The rule update is driven by the blackouts on the east coast which came to everyone's in 2003. Additionally the federal ruling is considered a matter of national security. Power line outages not only disrupt service but can be potentially hazardous to the general population. It has always been part of the routine maintenance protocols of PSE to review the conditions of the corridors in which lines are maintained and remove potential hazards as necessary. Regular maintenance circuit reviews are cyclic and each line in this area comes up for assessment every 3 to 5 years. In recognition of the federal mandates PSE has set specific goals which will improve over -all reliability and meet all Federal mandates within the next few years. Compliance with new FREC/NERC rules will be achieved by adhering to the newly standardized protocols PSE has created throughout the management corridors. The new protocol identifies tree species for removal based on a DBH (diameter at breast height) and projected height; based on growth standards for the species. The adopted protocol requires allowing only those species which are less then 6 inches DBH and determined to attain a maximum mature height of less then 15 feet. The new FERC/NERC rules call for two different Clearances from overhead transmission lines (distance of vegetation from the conductor) which must be developed by each owner of kV 230 lines. Clearance 1 is the distance which must be obtained at time of regular maintenance. Since our native species have several growth rates and mature heights, PSE has determined the need to develop Clearance 1 based on the maximum mature height of trees which are to be allowed within the Right of way and wire zone (12 feet to each side of the actual over head wire). After review of several Washington State native tree and shrub species, PSE has adopted 15 feet as the maximum allowed height in the corridor of maintenance. This process has also identified what distinct species will be allowable; this information will be coming out in a separate handout developed by PSE and sent to all parties with interest, responsible for review criteria and/or agencies). 2 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • The 15 foot standard is commonly used when considering height restrictions an the areas of power lines. The other Washington State owner of 230kV lines in this area is BPA. BPA uses 14 feet as the height maximum for all trees in their maintenance areas. Nationwide many other kV230 lines allow maximum 15 foot trees within the wire line areas. Clearance 2 determines the area which makes up the allowed distance between any vegetation and the transmission conductors; this distance must be kept clear at all times. PSE has determined the Clearance 2 allowed distance (which is to prevent flashover on 230 kV lines ) to be 6.8 feet. The federal guidelines for determining the Category 2 distance formula has been developed by IEEE (International Electrical and Electronics Engineers) and applied to adjust for the terrain in the area of the transmission lines. Based on this calculation, the distance for the type 2 Clearance equals 6.8 feet system wide. This criteria then established the area in which no vegetation is ever allowed regardless of the cyclic rotation of maintenance at the specific site. The design of 230kV transmission lines create a minimum ground clearance (as defined by the NESC / National Electrical Safety Code) between 22 and 25 feet at all times. When this minimum ground clearance height is juxtaposed to the minimum 6.8 foot type 2 Clearance, the result is close to the 15 feet maximum vegetation height allowance proposed by PSE . While review of any one specific area of the transmission line may result in a somewhat different final maximum and minimum height and separation distance; PSE must develop a final protocol which is followed system wide without variation. 3 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK w(ivt difrf V`e� ln/e p 4t v�rcl? (gGQ�� cionti-e) V cAj 2008 IMPACTS: 600-) fi.ed2 G117I/atr 41641 -(4) l I/ '71(Y �n7w X PSE and related consultants, document a proposed tree and shrub removals (including girdling in place) which fall within sensitive areas and /or tree retention areas. The program makes every effort to work with the regulating agency for each proposed work area in order to address and meet all code requirements. PSE provides 100% of required mitigation. This season Tukwila is one of the areas which has been targeted for regular vegetation maintenance and removal beginning May 1, 2008. This work area is defined on attached maps. Below is a listing of proposed removals within sensitive areas. TREE REMOVALS: 4 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK POBA(18) 6 " -12" black cottonwood Populas balsamifera POBA (7) 12 " -18" black cottonwood Populas balsamifera PSME(4) 6 " -12" Douglas fir Psuedotsuga menzeisii PINE (2) 6 " -12" Pine species Pinus ssp. PREM(1) 6 " -12" bitter cherry Prunus emarginata ACMA(5) 6 " -12" big -leaf maple Acer macrophyllum ACMA(7) 12 " -18" big -leaf maple Acer macrophyllum THPL (1) 6 " -12" Western red cedar Thuja plicata THPL (1) 12 " -18" Western red cedar Thuja plicata SALIX (259) 6 " -12" willow species Salix ssp. SALIX (15) 12 " -18" willow species Salix ssp. �°:.4Evd `4�., µ4 +� xx w .e'bxH�� , , ,.,:, _ ..... ,_', , R t+' , . ra�.�•ti`z`."�Ci�x,GPs�YN.�� i,,, i,:.. ,,,r. E4 >, „w, tt���eJy, ��.,�, � . 4 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK GENERAL INFORMATION The work proposed at this time will take place between: Thomas Guide page 655 (J4,H4 and H5, G5, J5 and J6,and J7) page 685 (J1) from Oaksdale Ave SW, Hway 405, Southcenter Boulevard and Tukwila Parkway South toSW43`dST • (Section 23, 24, 25, 26, and 36 Township 23 N; Range 4E) We have identified the following public streets and highways adjacent to the site as: • Tukwila Parkway • Private roads and parking areas of the Family Fun Center • Longacres Way • Strander Blvd has an unofficial access point • Private parking areas do provide access to he trail in several locations south of Strander though most are fenced, gates or controlled in some manner. Portions of the site served by public transit: • No direct access to the work sites, by the public or non - employees, are predicted The general area of work includes: portions of the City of Kent, City of Tukwila and City of Renton • Work site to include all areas under the transmission line and 12 feet on either side of the actual overhead line. • Portions of the work site are parallel to the Interurban Trail. • Work site areas may include portions of the "Interurban Trail" as well as the vegetated areas adjacent to the trail. Site work will not impact or alter the existing recreational use of the area other than those impacts created during the time when work when crews may need to keep areas clear for safety reasons. • Portions of the work site are parallel to commercial railroad tracks. To the best of our knowledge there are no commuter trains running adjacent to the any area of proposed work. 5 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • Portions of the work areas will fall within the Shoreline areas of the Green River and its related tributaries. • Due to the regular cyclic work within this 230 kV transmission corridor, no areas of hazard created by unfamiliar site conditions have been identified relative to crew safety. • All work will be conducted within the areas which have been routinely maintained by PSE for decades (as shown on the attached maps.) • Crews will use hand tools and gas operated hand held equipment. At times, where specially noted, a lift truck and bucket operated from the surface of the nearby trail, road or parking strip may be used to clear large hazardous trees. Trucks will not enter any vegetated areas. • There is no expected disturbance to soil in quantities in excess of 0.5 Cy at any work site area • There will be no appreciable changes to air quality in the location work is being conducted. • We are not aware of any other work in the area which would impact the proposed scheduled maintenance. • Other utilities which may be found in the area of the proposed work o Gas pipelines o Water or Sewer lines o Other lower voltage lines maintained by PSE or others Sensitive areas within and /or adjacent to the work site: • Some work will be conducted within areas designated or understood to be wetlands and/or their related buffers. If flows are present, required TESC (Temporary Erosions and Sedimentation Control) measures will be used. Flows are not expected during the work period. • Maps are included with this outline letter indicating the areas of proposed work. When possible environmental features we are aware of have been identified. Some areas proposed for work may include streams and their buffers. • No work is expected to adversely impact the soil conditions or water quality of surface waters in the work areas • There are no known threatened or endangered vegetation species within the work site. Waters of the Green River and related tributaries are indicated to provide habitat to ESA listed species. City information provided in regards to ESA species will be immediately incorporated into the process prior to start of work. 6 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK Types of vegetation found within the proposed areas of work: • Trees: alder, cottonwood, willow, maple, aspen, fir, cedar, pine, and non - native trees • Shrubs: willow, red osier dogwood, vine maple, spirea and others • Grasses: reed canary grass and upland grasses • Wet soil plants: cattail, buttercup, bull -rush, skunk cabbage Soils: Most of the city is mapped as Urban Land, indicating soils are or were covered with impervious surface or otherwise highly urbanized at the time of the King County soil survey, except for some area south of South 180th Street. The most commonly mapped valley soils are Nooksack silt loam, Newberg silt loam, and Woodinville silt loam, reflecting the alluvial nature of the sediments being deposited. These soil types were identified at most of the soil pits taken along the interurban trail headed south from 405 and the Family Fun Center. Soil pits were not taken in the area of proposed work within the Family Fun Center and its adjacent proposed work areas. Habitat conditions which are found within the areas of proposed work include: The total lineal feet for work in the Tukwila City Limits will be approx. 4 to 5 miles; though continuous management work along this length should not be necessary. Trees appear to grow in scattered areas; crews will move from one area to the next; completing work in each area before moving on. The affected wetlands are divided by transportation corridors and development. Studies conducted by the City indicate `Fragmentation of the wetlands has resulted in lower quality habitats with a high percentage of non - native, invasive species within the wetlands. The City's wetland inventory identifies relatively few wetlands within or adjacent to the Green / Duwamish River's shoreline planning area'. The wetlands that remain within the shoreline planning area are predominantly palustrine emergent and palustrine scrub /shrub habitat types as classified using the US Fish & Wildlife Service wetland classification system (Cowardin et al., 1979). These wetlands have limited functions in regards to the ability to detain surface water flows, maintain groundwater recharge and discharge interaction, provide significant habitat, and improve water quality. 7 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK Dense scrub -shrub vegetation habitats, within both upland and wetland soil rooting conditions, are found within the proposed work area. These areas are capable of providing significant (though low grade) habitat for small bird and urbanized mammal populations. Hunting raptors and small mammals may also find foraging opportunities in these small isolated environments. In addition, areas with flooded and seasonally ponded wetlands can provide life cycle habitat for small aquatic and semi aquatic species of amphibians and insects as well as foraging and watering areas for other species. Many of the wetland conditions along this right of way are populated with invasive grasses and blackberry brambles mixed with native shrubs and a variety of herbaceous vegetation mixed in. This habitat type provides foraging for smaller species and opportunities for shade and resting for other species. Within these area we have noted targeted species of trees which will require maintenance. Much of the proposed work areas fall adjacent to the Interurban Trail as well as within a busy light and heavy industrial area. Within the traffic areas, industrial zones and highly urbanized portions of the study locations the existing habitat values are low. Major impacts to the general habitat conditions, which could create new adverse impacts on those species found in these areas, is not expected Upland slope conditions (typically railroad ballast) provide the least habitat value in the areas of work and will also pose the least need for vegetation management. These habitat areas provide limited habitat features for those animal species using the area; such as small and medium mammals, amphibians, insects and regional or migrating birds. No work will be conducted within the waters of the streams or rivers within the transmission line right of ways without specific application for that work. All work conducted within the buffers of the Green River, its tributaries or its Shoreline will be mitigated per the City code. 8 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK SHORELINE REVIEW FROM TUKWILA SHORELINE PLAN Those lands extending landward for two hundred feet in all directions as measured on a horizontal plane from the ordinary high water mark; floodways and contiguous floodplain areas landward two hundred feet from such floodways; and all associated wetlands and river deltas (RCW 90.58.030(2)(f)). The City's current SMP designates all shorelines as "Urban" and employs a tiered system of regulations within the shoreline jurisdiction based on the distance from the Green River mean high water mark (MHWM). These tiered management zones within the Urban Environment are generally described below • River Environment/Zone: a 40 -foot wide zone extending landward from MHWM and having the most environmentally protective regulations; • Low - Impact Environment/Zone: the area between the River Environment and 100 feet from the MHWM; and • High- Impact Environment/Zone: the area between 100 and 200 feet from the MHWM. Work areas under the kV lines East and North of the Family Fun Park will take place adjacent to the Green River and /or its tributaries; including areas that may have some substantial rooting zone within the banks of the river. This work will then take place within the designated Shoreline Area of the Green River. The impacts zones will be: River Environment Zone (within 40 feet of the river) and the Low Impact Environmental Zone (within 100 feet of the river). This is in addition to the pocketed and isolated wetland environments found under the kV lines which may also be affected. Concerns within the Shoreline areas (as well as other critical areas) are: Surface Runoff from work and affects to site after work is complete Hydromodifications due to the change is vegetation Sediment Generation and Transport during and after maintenance work Water Quality throughout the life of the ongoing maintenance Protecting adverse affects to the groundwater recharge abilities Sediment transport due to disturbance within work area Nutrient loading from work areas and control activities Protection from adverse affects to the sites due to water temperature variations Protection of Transitional habitat Protection of sites ability for long term natural contribution of in channel LWD, 9 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK The proposed work seeks to limit all the adverse impacts noted above though careful hand work within all sensitive areas where possible. When work could affect the safety of the site in terms of life or property work will be conducted from a truck operated bucket set at the edge of existing travels areas (or parking locations). Silt fence will be placed if any soil work will create disturbance above or adjacent to the Green River or its tributaries Work within the ponded portions of the wetlands within the easement will include girdling and slash cutting; though no proposed soil excavation is included in this proposal General Habitat conditions will not be significantly altered. Proposal for maintenance includes the encouragement (and or planting) of dense scrub shrub habitats which will prevent and limit the re- growth of undesirable species. No areas for proposed maintenance appear to be within locations defined as major channel migration zones, bank failure or geologic hazards areas or river floodways. Current zoning: alternating type of use and designation found throughout the corridor work area Comprehensive Plan Designation: alternating type of use and designation found throughout the corridor work area Shoreline Designation: Green River Urban Shoreline Portions of work will take place within the buffer area of the Green River Existing Development: Private and Public recreational areas, Private commercial business, Railroad related businesses and tracks, Interurban Trail, High Voltage Tower pads, Herbicide application: • Accord XRT II State approved Aquatic Herbicide (MSDS label attached) SIGNATURE Prepared by Kim Peterson for PSE DATE: The entire text of FAC -003 -1 (NERC Vegetation Management Standard) : www.nerc.com/pub /sys /all updl/standards/sar/FAC- 10 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK 3 21 08 Calculations for areas of impact within the wetland environments along the railroad /interurban corridor running North to South. Wetland A area: The most Westerly linear wetland area shown on the map defined as an area approx. 2400 lineal feet above the Southern border of the City limits. This area has a portion which expands in size from East to West and comprises a total area of approx. 121,000 sf. The impact area will be limited to that which is adjacent to the kV lines and Interurban trail location (and linear in shape ) which will equal less then 1,000 sf. Wetland B This is the wetland area immediately under the kV lines. This area will encompass most of the work required in this project. Total wetland area has been calculated at approximately 5,300 lineal feet of wetland attributes with a few breaks in the contiguous nature of the wetland conditions. Some areas contain dense stands of willow and other species (native and non native) determined to be undesirable within the transmission line right of way. These trees will be killed in place and left standing whenever possible. No soil disturbance which would lead to continued turbidity in areas with flowing water is planned. Total are of impact will be les then100,000 square feet within a general area of over 196,000 square feet. In site walks in February and March 2008 there were some wetland areas noted along the Interurban Trail, throughout the full work area, which did contain waters with a visible flow pattern. It is assumed this is a groundwater action since many of the wetlands are not contiguous in nature and no stream system is noted in this same area. Wetland C This wetland area is noted on the East side of the kV lines and is not affected by this proposed work at this time. Total area within this wetland would exceed 50,000 sf. This wetland area is not contiguous to the work area. Calculations for the impact area of the Green River Urban Shoreline environment: Approximately 650 lineal feet of shoreline falls within areas which will be considered for maintenance. At this time the work is scattered and isolated and the total square footage of work area within the wetland will be approximately 2,500 to 4,000 square feet (within the 40 and 100 foot zone areas) Some clearing work is proposed for an area on the South shoreline, just north of the Family Fun Center, which appears to be a possible mitigation area. Trees have been planted directly within eh PSE easement. This area may require additional review for impacts to the mitigation and what implications this will pose. 11 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • Mitigation for proposed impacts: PSE is prepared to cooperate with the City of Tukwila on any required mitigation on or off site. Due to the complex nature of the clearing and cutting in regards to the FERC/NERC rules planting anything on site (at location of maintenance) will limit replacement species to low growing shrubs and very few trees. Impact total is expected to be approximately 100,000 square feet (2.30 acres) within a lineal, non - continuous, run of about 5,200 feet. On site mitigation could include: Planting of spirea and native rushes and grasses in the wetter and inundated areas Salmonberry, snowberry and other native shrubs in the drier wetland and upland locations. Wetland locations with maximum clearance to the wire could include Dogwood plantings Within the Shoreline area mitigation with shrub would be well within the allowance for vegetation height but not trees (such as those currently existing) will be acceptable for replanting. Replacement of existing mitigated trees (in the Family Fun Center area) will have to be located outside the wire zone (more then 12 feet from the outside wire areas). PSE is more then willing to work with the City for a centrally located mitigation site which meets the City needs and creates a specific location which can be adequately protected and maintained to add habitat values to a particular City owned (or private) site. Maintenance: PSE will need to conduct continued maintenance throughout the system; though the work being proposed at this time is aimed at lessening the repeated maintenance issues and need for yearly vegetation cuts through the removal of the identified species. Please feel free to contact me if you have any questions Kim Peterson Blue Heron Services Inc For PSE 360 793 7767 bheron @seanet.com 12 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • L_o2 -o l $ • PUGET SOUND ENERGY 74 c t'EialE® March 21, 2008 Eu LO MTV To: City of Tukwila OEVELPAdEN1i. From: Puget Sound Energy / ArborMetrics Solutions, Inc. / Blue Heron Services, Inc. Contact: Cate Burnett / ArborMetrics Solutions, Inc. (206)718 -8216 Contact: Kim Peterson / Blue Heron Services, Inc. (360) 793 -7767 MAR 2 6 20 PSE VEGETATION MANAGEMENT - INTERURBAN TRAIL PROJECT PROPOSAL PSE and associated contractors and consultants are submitting this outline of proposed work as requested at the February 14t 2008 meeting. PROPOSED VEGETATION REMOVAL Tree maintenance and vegetation control will primarily consist of girdling targeted species (chain saw cut around the girth of the standing tree); lowering of canopy (cutting and dropping limbs) if necessary for safety and finally applying a state approved aquatic herbicide (details attached.) Trees will be left standing in place unless they pose a threat to users of adjacent public rights of way or railroads. By eliminating the need for brush removal at the time of maintenance work, damage to the natural habitat and resources in the area of maintenance will be kept to a minimum. In addition, allowing trees to remain standing will provide additional and changing habitat values within the wetland and buffer areas. Hand cutting and removal, as well as tlimited a earin will lessen all soil impacts; no soil impacts are expected other then slight disturbance along pathways used for access This maintenance procedure does include the application of herbicides as a final component of the process. Herbicide application will be thorough low- pressure hand application of herbicide to each tree which is cut or girdled. All herbicides will meet requirements of the State of Washington, King County and any City local regulations. Additional herbicide information is attached to this outline of proposed work. The work referenced in this outline is an extension of the continual on -going maintenance which is conducted by PSE within its easements. This specific control work will continue into the future, as necessary, with the goal of meeting the Federal mandates for the continued safe operation of the 230kV transmission lines. 1 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • PSE VEGETATION MANAGEMENT — FERC AND NERC MANDATES The work defined in this outline will be conducted in conformance with the recent updated FERC/NERC rules. Federal requirements (FERC and NERC regulations) mandate that all owners of 230kV transmission lines create protocols for management which will assure the minimum security defined in the recent rulings. HISTORY AND UPDATE: This recent. more stringent. FERC/NERC regulations require more specific maintenance procedures and protocols for the regular maintenance work conducted. These requirements include clear and concise definitions for trees species which will not be allowed within the transmission line right of ways and must be removed. The rule update is driven by the blackouts on the east coast which came to everyone's in 2003. Additionally the federal ruling is considered a matter of national security. Power line outages not only disrupt service but can be potentially hazardous to the general population. It lias7always7been ;part.ofthe,routine;maintenance prot co ols ofPSE'to'reviewrthe conditions ofathe corridorsjn Whichluies.are maintained,and .remove potential hazards as'necessary Regular maintenances cg„i-rcuitrrevie scycliaraiand:each?li a mptlii a eaacomes3upifor assessinent;everyj3rtofi5 years In recognition of the federal mandates PSE has set specific goals which will improve over -all reliability and meet all Federal mandates within the next few years. Compliance with new FREC/NERC rules will be achieved by adhering to the newly standardized protocols PSE has created throughout the management corridors. The new protocol identifies tree species for removal based on a DBH (diameter at breast height) and projected height; based on growth standards for the species. 1Th adop ediprotocol requiresdallowmg7 o lg.Etho iea which ±a a les then 6 inchesrDBH ah&determined <toYandifi maximum,mature heiglby of:.lessthenl'5 °feet.: The new�FERC%NERC Ies calrfor two different Clearancessfrom o erhead transmissionlines (distancet'of vegetatibnlfro helcon'ductor)1whi htmusttli develapedibyl acWWTh'2 offkV1 32 0 roes ff, Clearance? l5is:;the distance which mtigibeobtairiedra rtti em of regular mamteriance: Since our native species have several growth rates and mature heights, PSE has determined the need to develop Clearance 1 based on the maximum mature height of trees which are to be allowed within the Right of way and wire zone (424feet ,to eachTsidej ofithe actual over liead wire) AfterSreview -of seeralsWashingtom •Statemative,tre� a d(shrub) species PSE has .adopted• �l`5 s;,theimaxirrium allowedtheightzin'the`corndoriof mamtenanee? This process has also identified =wliatedistinct s 5WiiesFwill be: allowable; fliis:uiformafion will be coming &out in,aiseparate'handoutrd ve elopedib IRSE and,°sentrto all•- •partiesFwrth interest responsible' for review criteria d%or agencies). 2 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK 1 • The 15 foot standard is commonly used when considering height restrictions an the areas of power lines. The other Washington State owner of 230kV lines in this area is BPA. BPA uses 14 feet as the height maximum for all trees in their maintenance areas. Nationwide many other kV230 lines allow maximum 15 foot trees within the wire line areas. C�leeaance 2_dete fi thearea whicl makes -upahe.allowed.d st-ariali.Ttwe any vegetation'annif transmissio cn ondu ctors; this distance must be kept clear at all times. POSE hasydetermine`d:the Clearan ec 2 ta11� ow d' >dist e4(which-is to; preventF:flashover -on ., .. 630'kV''lines) o be�6 8 -f 'eta The federal guidelines for determining the Category 2 distance formula has been developed by IEEE (International Electrical and Electronics Engineers) and applied to adjust for the terrain in the area of the transmission lines. Based on this calculation, theTdistance for_thet pe 2 Clearance equals;.6:8feet¢systerri wide A This criteria then established the area in which no vegetation is ever allowed regardless of the cyclic rotation of maintenance at the specific site. The design of 23-01 trans ssion7lines" create, a;minimum°groundrelearance (as defined by the NESC / National Electrical Safely Code), between-22-and7253feeratfall "times:. When this minimum ground clearance height is juxtaposed to the minimum 6.8 foot type 2 Clearance, the result is close to the 15 feet maximum vegetation height allowance proposed by PSE . Whil"eeiew of any::orie3'specif c.area?.of theltransmission4linelmay resultnn,a -somewhat differ`_ent firialrmaximum and minimum =height` ndA*.separations,,di stance; PSE,,must develop] a finalFprotocolTwhich'is followed,s sy tem wideswitlioutlyariation] 3 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK 1 • 2008 IMPACTS: PSE and related consultants, document all proposed tree and shrub removals (including girdling in place) which fall within sensitive areas and /or tree retention areas. The program makes every effort to work with the regulating agency for each proposed work area in order to address and meet all code requirements. PSE provides 100% of required mitigation. This season Tukwila is one of the areas which has been targeted for regular vegetation maintenance and removal beginning May I, 2008. This work area is defined on attached maps. Below is a listing of proposed removals within sensitive areas. TREE REMOVALS: ,L y `{K . rN + K,.SU`�. s^'? $, ' ' - Ki . t'4,P Mq ; , � _ h X� � 4?YU„" ,.'..i`... ��.�t.�1gK,N,�',}N & wdf •?`` d .�i `"s�'rd /" " 14 3^�' - _'a H. ••. 'S 9 ,..., .Aa i ✓<y`rt mb;kA'a�i".s`i" POBA(18) 6 " -12" black cottonwood Populas balsamifera POBA (7) 12 " -18" black cottonwood Populas balsamifera PSME(4) 6 " -12" Douglas fir Psuedotsuga menzeisii PINE (2) 6 " -12" Pine species Pinus ssp. PREM(1) 6 " -12" bitter cherry Prunus emarginata ACMA(5) 6 " -12" big -leaf maple Acer macrophyllum ACMA(7) 12 " -18" big -leaf maple Acer macrophyllum THPL (1) 6 " -12" Western red cedar Thuja plicata THPL (1) 12 " -18" Western red cedar Thuja plicata SALIX (259) 6 " -12" willow species Salix ssp. SALIX (15) 12 " -18" willow species Salix ssp. - T K .y 'e._• iw ` "t Y ti' Y�'8 €�' 'le A;� y Y 4 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • GENERAL INFORMATION The work proposed at this time will take place between: Thomas Guide page 655 (J4,H4 and H5, G5, J5 and J6,and J7) page 685 (J1) from Oaksdale Ave SW, Hway 405, Southcenter Boulevard and Tukwila Parkway South toSW43`dST • (Section 23, 24, 25, 26, and 36 Township 23 N; Range 4E) We have identified the following public streets and highways adjacent to the site as: • Tukwila Parkway • Private roads and parking areas of the Family Fun Center • Longacres Way • Strander Blvd has an unofficial access point • Private parking areas do provide access to he trail in several locations south of Strander though most are fenced, gates or controlled in some manner. Portions of the site served by public transit: • No direct access to the work sites, by the public or non - employees, are predicted The general area of work includes: portions of the City of Kent, City of Tukwila and City of Renton • Work site to include all areas under the transmission line and 12 feet on either side of the actual overhead line. • Portions of the work site are parallel to the Interurban Trail. • Work site areas may include portions of the "Interurban Trail" as well as the vegetated areas adjacent to the trail. Site work will not impact or alter the existing recreational use of the area other than those impacts created during the time when work when crews may need to keep areas clear for safety reasons. • Portions of the work site are parallel to commercial railroad tracks. To the best of our knowledge there are no commuter trains running adjacent to the any area of proposed work. 5 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • Portions of the work areas will fall within the Shoreline areas of the Green River and its related tributaries. • Due to the regular cyclic work within this 230 kV transmission corridor, no areas of hazard created by unfamiliar site conditions have been identified relative to crew safety. • All work will be conducted within the areas which have been routinely maintained by PSE for decades (as shown on the attached maps.) • Crews will use hand tools and gas operated hand held equipment. At times, where specially noted, a lift truck and bucket operated from the surface of the nearby trail, road or parking strip may be used to clear large hazardous trees. Trucks will not enter any vegetated areas. • There is no expected disturbance to soil in quantities in excess of 0.5 Cy at any work site area • There will be no appreciable changes to air quality in the location work is being conducted. • We are not aware of any other work in the area which would impact the proposed scheduled maintenance. • Other utilities which may be found in the area of the proposed work o Gas pipelines o Water or Sewer lines o Other lower voltage lines maintained by PSE or others Sensitive areas within and /or adjacent to the work site: • Some work will be conducted within areas designated or understood to be wetlands and/or their related buffers. If flows are present, required TESC (Temporary Erosions and Sedimentation Control) measures will be used. Flows are not expected during the work period. • Maps are included with this outline letter indicating the areas of proposed work. When possible environmental features we are aware of have been identified. Some areas proposed for work may include streams and their buffers. • No work is expected to adversely impact the soil conditions or water quality of surface waters in the work areas • There are no known threatened or endangered vegetation species within the work site. Waters of_the GreenRicersarid =related`aributarieTare indicatedcto:prov_id "e (habit-44o >ESA lis'ted'species Ei_ty, infFrin'' tion proviiiatin-regardsyto7ESA ispeciesF. wiill 'beimmediatelyaincorporated into;theprgcesspnor�to• tart of<work 6 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK 1 • Types of vegetation found within the proposed areas of work: • Trees: alder, cottonwood, willow, maple, aspen, fir, cedar, pine, and non - native trees • Shrubs: willow, red osier dogwood, vine maple, spirea and others • Grasses: reed canary grass and upland grasses • Wet soil plants: cattail, buttercup, bull -rush, skunk cabbage Soils: Most of the city is mapped as Urban Land, indicating soils are or were covered with impervious surface or otherwise highly urbanized at the time of the King County soil survey, except for some area south of South 180th Street. The most commonly mapped valley soils are Nooksack silt loam, Newberg silt loam, and Woodinville silt loam, reflecting the alluvial nature of the sediments being deposited. These soil types were identified at most of the soil pits taken along the interurban trail headed south from 405 and the Family Fun Center. Soil pits were not taken in the area of proposed work within the Family Fun Center and its adjacent proposed work areas. Habitat conditions which are found within the areas of proposed work include: The total lineal feet for work in the Tukwila City Limits will be approx. 4 to 5 miles; though continuous management work along this length should not be necessary. Trees appear to grow in scattered areas; crews will move from one area to the next; completing work in each area before moving on. The affected wetlands are divided by transportation corridors and development. Studies conducted by the City indicate `Fragmentation of the wetlands has resulted in lower quality habitats with a high percentage of non - native, invasive species within the wetlands. The City's wetland inventory identifies relatively few wetlands within or adjacent to the Green / Duwamish River's shoreline planning area'. The wetlands that remain within the shoreline planning area are predominantly palustrine emergent and palustrine scrub /shrub habitat types as classified using the US Fish & Wildlife Service wetland classification system (Cowardin et al., 1979). These wetlands have limited functions in regards to the ability to detain surface water flows, maintain groundwater recharge and discharge interaction, provide significant habitat, and improve water quality. 7 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK Dien es scrub=shrubwegetation habitatssrwitliin:both upl nd a ndrwetland7soihrooting _conditiorisg, are found-withi n- the -proposed_;workarea Theserareaswe capable.of.providing significarit (thoughlow grade);habitat'for small. bird; andr urbanizedimammal °populationsHuntingwraptorsl and sn allcmammals_may also, findforaging opportunitiesamthese_srrall solated= environments., In addition, areas with flooded and seasonally ponded wetlands can provide life cycle habitat for small aquatic and semi aquatic species of amphibians and insects as well as foraging and watering areas for other species. Many of the wetland conditions along this right of way are populated with invasive grasses and blackberry brambles mixed with native shrubs and a variety of herbaceous vegetation mixed in. This habitat type provides foraging for smaller species and opportunities for shade and resting for other species. Within these area we have noted targeted species of trees which will require maintenance. Much of the proposed work areas fall adjacent to the Interurban Trail as well as within a busy light and heavy industrial area. Within the traffic areas, industrial zones and highly urbanized portions of the study locations the existing habitat values are low. Major impacts to the general habitat conditions, which could create new adverse impacts on those species found in these areas, is not expected Upland slope conditions (typically railroad ballast) provide the least habitat value in the areas of work and will also pose the least need for vegetation management. These habitat areas provide limited habitat features for those animal species using the area; such as small and medium mammals, amphibians, insects and regional or migrating birds. N , o;workmih be conducted`- within the ;waters of the streams;or ti a sr withii the transmission line; ri ht of way_s;, without -specific applicationfor that work? S.._g ' - AlLW .6ilaonducted7withrn'thebuffers of theTGreen{ River; itsTtributarieoats_Shoreline will'ber Finitigated' per the Citycode. 8 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • SHORELINE REVIEW FROM TUKWILA SHORELINE PLAN Those lands extending landward for two hundred feet in all directions as measured on a horizontal plane from the ordinary high water mark; floodways and contiguous floodplain areas landward two hundred feet from such floodways; and all associated wetlands and river deltas (RCW 90.58.030(2)(f)). The City's current SMP designates all shorelines as "Urban" and employs a tiered system of regulations within the shoreline jurisdiction based on the distance from the Green River mean high water mark (MHWM). These tiered management zones within the Urban Environment are generally described below • River Environment/Zone: a 40 -foot wide zone extending landward from MHWM and having the most environmentally protective regulations; • Low - Impact Environment/Zone: the area between the River Environment and 100 feet from the MHWM; and • High - Impact Environment/Zone: the area between 100 and 200 feet from the MHWM. Work areas under the kV lines East and North of the Family Fun Park will take place adjacent to the Green River and/or its tributaries; including areas that may have some substantial rooting zone within the banks of the river. This work will then take place within the designated Shoreline Area of the Green River. The impacts zones will be: River Environment Zone (within 40 feet of the river) and the Low Impact Environmental Zone (within 100 feet of the river). This is in addition to the pocketed and isolated wetland environments found under the kV lines which may also be affected. Concerns within the Shoreline areas (as well as other critical areas) are: Surface Runoff from work and affects to site after work is complete Hydromodifications due to the change is vegetation Sediment Generation and Transport during and after maintenance work Water Quality throughout the life of the ongoing maintenance Protecting adverse affects to the groundwater recharge abilities Sediment transport due to disturbance within work area Nutrient loading from work areas and control activities Protection from adverse affects to the sites due to water temperature variations Protection of Transitional habitat Protection of sites ability for long term natural contribution of in channel LWD, 9 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK The proposed work seeks to limit all the adverse impacts noted above though careful hand work within all sensitive areas where possible. When work could affect the safety of the site in terms of life or property work will be conducted from a truck operated bucket set at the edge of existing travels areas (or parking locations). Silt fence will be placed if any soil work will create disturbance above or adjacent to the Green River or its tributaries Work within the ponded portions of the wetlands within the easement will include girdling and slash cutting; though no proposed soil excavation is included in this proposal General'Haliitat co ditio sn will of be significantlyaltered 7Proposal for maintenance includes theericouragemenf(and.or plantmg)fof�dense-scrub shrub' hahitatsjwhichwill�prev 'ent:and "1'imit th ye re growth,'of undesi lile.species. /j N:o0 ea for pr615. riaii._, ce appear torbe .within locatiorisy definedfasr,majoorrTcchannel ..• gration- zones;zbank failure geologic.hazardsareas orriver floodways., Current zoning: alternating type of use and designation found throughout the corridor work area Comprehensive Plan Designation: alternating type of use and designation found throughout the corridor work area Shoreline Designation: Green River Urban Shoreline Portions of work will take place within the buffer area of the Green River Existing Development: Private and Public recreational areas, Private commercial business, Railroad related businesses and tracks, Interurban Trail, High Voltage Tower pads, Herbicide application: • Accord XRT II State approved Aquatic Herbicide (MSDS label attached) SIGNATURE Prepared by Kim Peterson for PSE DATE: The entire text of FAC -003 -1 (NERC Vegetation Management Standard) : www.nerc.com/pub /sys /all upol /standards /sar /FAC- 10 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK • • 3 21 08 Calculations for areas of impact within the wetland environments along the railroad /interurban corridor running North to South. Wetland A area: The most Westerly linear wetland area shown on the map defined as an area approx. 2400 lineal feet above the Southern border of the City limits. This area has a portion which expands in size from East to West and comprises a total area of approx. 121,000 sf. The impact area will be limited to that which is adjacent to the kV lines and Interurban trail location (and linear in shape ) which will equal less then 1,000 sf. Wetland B This is the wetland area immediately under the kV lines. This area will encompass most of the work required in this project. Total wetland area has been calculated at approximately 5,300 lineal feet of wetland attributes with a few breaks in the contiguous nature of the wetland conditions. Some areas contain dense stands of willow and other species (native and non native) determined to be undesirable within the transmission line right of way. These trees will be killed in place and left standing whenever possible. No soil disturbance which would lead to continued turbidity in areas with flowing water is planned. Total are of impact will be les then100,000 square feet within a general area of over 196,000 square feet. In site walks in February and March 2008 there were some wetland areas noted along the Interurban Trail, throughout the full work area, which did contain waters with a visible flow pattern. It is assumed this is a groundwater action since many of the wetlands are not contiguous in nature and no stream system is noted in this same area. Wetland C This wetland area is noted on the East side of the kV lines and is not affected by this proposed work at this time. Total area within this wetland would exceed 50,000 sf. This wetland area is not contiguous to the work area. Calculations for the impact area of the Green River Urban Shoreline environment: Approximately 650 lineal feet of shoreline falls within areas which will be considered for maintenance. At this time the work is scattered and isolated and the total square footage of work area within the wetland will be approximately 2,500 to 4,000 square feet (within the 40 and 100 foot zone areas) Some clearing work is proposed for an area on the South shoreline, just north of the Family Fun Center, which appears to be a possible mitigation area. Trees have been planted directly within eh PSE easement. This area may require additional review for impacts to the mitigation and what implications this will pose. 11 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK 1 • Mitigation for proposed impacts: PSE is prepared to cooperate with the City of Tukwila on any required mitigation on or off site. Due to the complex nature of the clearing and cutting in regards to the FERC/NERC rules planting anything on site (at location of maintenance) will limit replacement species to low growing shrubs and very few trees. Impact total is expected to be approximately 100,000 square feet (2.30 acres) within a lineal, non - continuous, run of about 5,200 feet. On site mitigation could include: Planting of spirea and native rushes and grasses in the wetter and inundated areas Salmonberry, snowberry and other native shrubs in the drier wetland and upland locations. Wetland locations with maximum clearance to the wire could include Dogwood plantings Within the Shoreline area mitigation with shrub would be well within the allowance for vegetation height but not trees (such as those currently existing) will be acceptable for replanting. Replacement of existing mitigated trees (in the Family Fun Center area) will have to be located outside the wire zone (more then 12 feet from the outside wire areas). PSE is more then willing to work with the City for a centrally located mitigation site which meets the City needs and creates a specific location which can be adequately protected and maintained to add habitat values to a particular City owned (or private) site. Maintenance: PSE will need to conduct continued maintenance throughout the system; though the work being proposed at this time is aimed at lessening the repeated maintenance issues and need for yearly vegetation cuts through the removal of the identified species. Please feel free to contact me if you have any questions Kim Peterson Blue Heron Services Inc For PSE 360 793 7767 bheron @seanet.com 12 PSE CITY OF TUKWILA LETTER OF PROPOSED WORK CITY OF TUKWILA Department of Community Development 6300 Southcenter Boulevard, Tukwila, WA 98188 Telephone: (206) 431 -3670 FAX (206) 431 -3665 E- mail.: tukplan(a1,ci.tukwila.wa.us RECEIVED MAR 26 2008 COMMUNITY DEVELOPMENT AFFIDAVIT OF OWNERSHIP AND HOLD HARMLESS PERMISSION TO ENTER PROPERTY STATE OF WASHINGTON ss COUNTY OF KING The undersigned being duly sworn and upon oath states as follows: 1. I am the current owner of the property which is the subject of this application. 2. All statements contained in the applications have been prepared by me or my agents and are true and correct to the best of my knowledge. 3. The application is being submitted with my knowledge and consent 4. Owner giants the City, its employees, agents, engineers, contractors or other representatives the right to enter upon Owner's real property, located at pair e•'[: i $ e ry. cv t t S for the purpose of application review, for the limited time necessary to complete that purpose. 5. Owner agrees to hold the City harmless for any Toss or damage to persons or property occurring on the private property during the City's entry upon the property, unless the loss or damage is the result of the sole negligence of the City. 6. Non - responsiveness to a City information request for ninety (90) or more days, shall be cause to cancel the application(s) without refund of fees. EXECUTED at IV`- (A'ac V 0C (city), (i., (state), on 3- — Z 20 08 Print Name C of,)(2' 4-0 (11--je Address J J S k t v AVE i` :€ Se Lc-C.- V li G J Phone Number 2 S 3. 673D. 2 t Signature On this day personally appeared before me i6rc y a/ to me known to be the individual who executed the foregoing instrument and acknowledged that helshe signed the same as his/her voluntary act and deed for the uses and purposes mentioned therein. SUBSCRIBED AND SWORN TO BEFORE ME ON THIS Z S DAY OF ,4/ re /1 ,20 d 3 NOTARY PUBLIC in and for the State of Washington residing at We off Q' My Commission expires on / / //e. /j/ P:1Planning Forms \Appli cations \2007 Applications \SPDirector- 12- 07.doc CITY OF TUKWILA Department of Community Development 6300 Southcenter Boulevard, Tukwila WA 98188 Telephone: (206) 431 -3670 FAX (206) 431 -3665 E -mail: tukplan@ci.tukwila.wa.us . •E VEC °VP'§- PECIAL PERMISSION DIRECTOR APPLICATION NAME OF PROJECT/DEVELOPMENT: F e 2 co g M 0 (cn nc LOCATION OF PROJECT/DEVELOPMENT: Give street address or, if vacant, indicate lot(s), block and subdivision, access street, and nearest intersection. �G1 c0 VIA Cc S 6 icy (O5 S (j-q- (I EA 4-, 4 C ) 5 S S T(' 7 `7) Pa 44,LC y Sow{ --G, --ko .43 re4 (mot {� (cis }5i LIST ALL TAX LOT NUMBERS (this information may be found on your tax statement). DEVELOPMENT COORDINATOR : The individual who: • has decision making authority on behalf of the owner /applicant in meetings with City staff, • has full responsibility for identifying and satisfying all relevant and sometimes overlapping development standards, and • is the primary contact with the City to whom all notices and reports will be sent. / Ina 1 -- PSC Name: C - v Address: �rO P. O. Pox .108408 Phone: t=64- 4S (093'7 2053 690 S, yya(o 6011) AX: Eikalw , wA •41706/ E -mail: rt _ _ : - -- _- 4 -- -/ ina , ma I' ri ! 0 - pse , c cm Signature: ( l eZaddy- Date: 3 2-4- ` OA/ P:\Planning Forms Applications \SPDirector- 6 -06.doc December 4, 2006 FOR STAFF USE ONLY Permits Plus Type: F-SP Planner: File Number: L,Og' - Ott Application Complete (Date: ) Project File Number: Prig _ 06,g Application Incomplete (Date: 5/lio log ) Other File Numbers: G0 2 - pas (5PA) NAME OF PROJECT/DEVELOPMENT: F e 2 co g M 0 (cn nc LOCATION OF PROJECT/DEVELOPMENT: Give street address or, if vacant, indicate lot(s), block and subdivision, access street, and nearest intersection. �G1 c0 VIA Cc S 6 icy (O5 S (j-q- (I EA 4-, 4 C ) 5 S S T(' 7 `7) Pa 44,LC y Sow{ --G, --ko .43 re4 (mot {� (cis }5i LIST ALL TAX LOT NUMBERS (this information may be found on your tax statement). DEVELOPMENT COORDINATOR : The individual who: • has decision making authority on behalf of the owner /applicant in meetings with City staff, • has full responsibility for identifying and satisfying all relevant and sometimes overlapping development standards, and • is the primary contact with the City to whom all notices and reports will be sent. / Ina 1 -- PSC Name: C - v Address: �rO P. O. Pox .108408 Phone: t=64- 4S (093'7 2053 690 S, yya(o 6011) AX: Eikalw , wA •41706/ E -mail: rt _ _ : - -- _- 4 -- -/ ina , ma I' ri ! 0 - pse , c cm Signature: ( l eZaddy- Date: 3 2-4- ` OA/ P:\Planning Forms Applications \SPDirector- 6 -06.doc December 4, 2006 Vegetation and reliable power - New tree removal requirements - In response to national and regional power outages within the past several years, the North American Electric Reliability Corporation (NERC), the organization in charge of improving the reliability and security of the bulk power system in North America, has adopted new vegetation management standards for electric transmission lines. The new stan- dards are designed to reduce tree - related transmission system outages. Heat and the elements can cause the lines to sag - so trees not only grow into the lines but the lines sag into the trees causing outages. Because of these new standards, Puget Sound Energy is changing the way it manages transmission rights of way. Previously, we only pruned tall grow- ing trees within our transmission rights of way, however with the new NERC standards, PSE must remove these tall growing trees. Specifically, we will remove vegetation that matures at a height of more than 15 feet from the areas underneath and beside our transmission rights of way - known as the wire and border zones. Problem trees growing under transmission lines Keeping the wire and border zones clear around transmission lines is the most effective way to reduce tree - related power outages. Wire zone The wire zone is the area directly underneath the transmission line, extending for a few feet on either side of the lines. In this area, PSE will remove all vegetation with a mature height of more than 15 feet, regardless of the present size of the vegetation. Border zone The border zone is located along those portions of rights of way not located directly beneath the trans- mission lines. Generally, we remove trees that mature at a height of greater than 15 feet. Some trees with a height of greater than 15 feet may be allowed to remain in the wire zone provided that they can be pruned in a manner that allows sufficient clearance from the lines. Danger tree zone The danger tree zone is located outside of PSE's right of way. PSE will remove any tree that poses a risk of falling into the transmission lines. Danger tree zone Border Wire zone Border. Danger zone zone tree zone List of compatible trees The following plants are compatible with transmission lines; their mature height is less than 15 feet. Common name Almond, Halls Hardy Double Viburnum Forsythia Hydrangea Indian Plum Lilac Mock Orange Mugo Pine Ocean Spray Oregon Grape Pacific Ninebark Red Flowering Currant Red Osier Dogwood Salal Salmonberry Smoketree Spiraea, Hardhack Staghorn Sumac Strawberry Bush Subalpine Spirea PUGET SOUND ENERGY The Energy To De Great rh,ree Compatible trees under transmission lines Tree Removal: New Requirements The new standards apply to The new NERC vegetation standards cover transmission lines with voltages of 200 kilovolts (kV) or higher. On our system, the new vegetation management standards will apply to our 327 miles of 230 kV lines in Chelan, Douglas, Grant, King, Kitsap, Kittitas, Pierce, Skagit, Snohomish and Whatcom counties. The standards do not apply to our 115 kV transmission lines or distribution lines. What are transmission lines? Transmission lines safely transport high voltage electricity from power sources like dams and wind farms to substations in local communities. Transmission normalcy takes place at voltages of 115 kV and higher. Applying NERC standards to our vegetation management practices surrounding 230 kilovolt transmission lines What are distribution lines? Distribution lines are critical links in the electrical system connecting substations and transformers directly to homes or businesses. Unlike transmission lines, distribution lines typically carry less than 69 kV. Distribution lines can be installed both above and below ground. PSE.com 4330 1/08 For more information go to www.nerc.com www.eere.energy.gov www.scc.wa.gov www.dnr.wa.gov www.arborday.com TREE LINE USA. Puget Sound Energy P.O. Box 90868 Bellevue, WA 98009 -0868 1.888.225.5773 PUGET SOUND ENERGY The Energy To Do Great Things PRINTED WITH SOY INK �. F. • •e2 !� :4 42.40. ... . &§ , ¥. ' •rte \ • • S &N§ ENEEGY »» Star magnolia // © m Dwarfipanared pine r0—±fttall 7O-2 feet tall . m . • • here trees in both rural and urban settings are a vital element to the quality of life. Trees provide us with wood products, wild -life habitat and watershed protection. Trees can provide shade and privacy, serve as a windbreak, and provide energy savings (both heating and cooling) if properly placed. However, when trees are improperly placed, they can become a hazard. HELP SOLVE A GROWING PROBLEM TO KEEP THE LIGHTS ON Reliable electric service is also a vital part of our quality of life. When tree limbs come in contact with power lines, electrical service can be interrupted. A large portion of power outages affecting Puget Sound Energy customers in recent years were caused by trees. Fallen trees and tree limbs that become entangled in lines, wind -blown branches that cross the lines as they fall to the ground, and tree limbs that grow into power lines are the major causes of outages. Not only are such service interruptions inconvenient for customers, but they can also threaten public safety when power is interrupted to vital services such as hospitals, traffic signals, fire alarm systems, or customers with life support systems. In addition, because the moisture in and on trees can also conduct electricity, a -y — tree in a power line can be hazardous for children and others nearby. A SAFE SOLUTION As part of our obligation to provide reliable electrical service to our customers, we regularly trim, and occassionally, remove trees posing a risk to overhead ,,,power lines. Proper pruning, selective removal of tree ath „and discriminating use of growth regulators erbici.des are among the methods employed. • • PLAN BEFORE YOU PLANT Choosing the right tree and the best place to plant will help provide beautiful, healthy trees that need little maintenance. To ensure reliable electric service for the future, special care must be taken in the selection and placement of newly planted trees near power lines. Wise tree planting also protects street and side- walk visibility and clearance, and prevents damage to pavement, sewers and buildings. Careful tree selection should accommodate how you plan to use the site as well as safety needs. In addition, properly located trees can increase property values. The care taken to plant the right tree in the right place is an investment in the future. Consider the site evaluation worksheet on the following page before selecting and planting trees or shrubs. We have prepared this book to provide our customers with guidelines for sound tree management, placement and selection so that trees planted today leave a legacy of beauty and safety. CONTENTS Tools to help plan your landscaping 2 Site evaluation worksheet 3 How To Guide for planting trees and shrubs 4 Safe planting near pad - mounted transformers 5 Tree selection 5 -6 Recommended trees and shrubs 7 -18 Plant selection index 19 Native plant selection index 20 Long -term tree care 21 -22 Sources, additional resources and acknowledgments 23 0 • • TOOLS TO HELP PLAN YOUR LANDSCAPING Before planting trees and shrubs, consider what you want your yard to look like in 10 or 20 years. Then, take an inventory of the factors that impact your site. (The "Site Evaluation Worksheet" on page three of this guide will help you to complete this step.) Using a standard piece of graph paper, map out your yard, house, driveway, street, power lines and other existing immovable elements. Then, consider where trees and shrubs can be added to complement your site. Here are some things to consider when making your decisions: Evergreeit� ion northweste Aside �b1 ck 'winter winds. Winter winds (,j \rte f . bso smaltltrees thatgrow to a;maximum bet fl�2.S�f�et�4-,�n planting near power - lines. radi tion :warm your:: - home during • the winter. Power line Property line Deciduous tree Evergreen tree Shrub/hedge spreading tree‘near eetv walk- least1,0fiftlte, mature,tr ;sha.pe will be. columnar or pyramidal. SITE EVALUATION WORKSHEET How close is the site to: other trees? ft. buildings? ft. utility wires? ft. sidewalks, driveways, etc.? ft. underground utilities? ft. Is the soil type: well drained? YES NO poorly drained? YEs NO acidic? YES NO alkaline? YES NO Will the tree be: irrigated? YEs NO Will the tree receive: full sun? YES No partial sun? YES NO full shade? YES NO What is the tree exposure: south or west? YES No north or east? YES No Reason for planting the tree: fall color YES NO spring flowers YES NO wildlife enhancement YEs NO to create a screen YES NO fruit bearing YEs NO windbreak YES NO When the tree matures, will it: be larger than I really want? YEs NO block my view? YES NO block my neighbors view? YES NO shade my home in the summer? YEs No shade my home in the winter? YEs NO Have you called to have underground utilities located? YES NO Have you contacted your local municipality to determine if any permits are required to plant the tree? YES NO • ension Conservationi5ervice or a' 1ocatsnurseryfor soilItest laboratories iii your area " siatewt0i*or atIl 800 553 434gui!liittitas.county to have utilities'marked for you free of charge. • • HOW TO PLANT TREES AND SHRUBS Remember to locate all underground utilities before you STEP begin. Washington state law requires that you notify local utilities at least two business days in advance of digging. Contact the Utilities Underground Location Center (statewide number: 1-800-424-5555 or Kittitas county: 1- 800 -553- . 4344) to have all local utilities contacted for you free of charge. Dig the planting hole two to three times the width and the s 7p same depth as the ball or container. Leave the bottom of the hole solid. Loosen the soil on the sides of the hole with a shovel or spade fork. For balled or burlapped trees, set the root ball in the hole and remove as much burlap as possible. Be sure to remove all twine or wires from around the base of the tree and the top of the root ball. For container trees, remove the tree from the container and straighten any coiled roots. With a shovel or knife, cut any circling roots on the side of the root ball. Loosen the root ball to stimulate root growth into the surrounding soil. Lower the tree into the planting hole by supporting the root ball. For bare -root trees, prune out damaged or tightly circling roots. Plant only during the dormant season. Keep roots covered and moist before planting. Place the tree in the planting hole, spread the roots and cover with soil except in high clay or sand conditions. Make sure no roots are curled up or tucked under. Fill the planting hole and cover the root ball with the same soil EP dug from the hole. Avoid using soil amendments like peat moss or composted organic material in the planting hole (except in soils with very high clay or sand content). If you are unsure, please check with your local nursery. Water well, slowly soaking the soil to the full depth of the root strEp ball. Because water does not move easily between different soil f textures, be sure to also apply water directly to the root ball as well as to surrounding soil. Repeat watering in three days. Mulch the area extending approximately two feet from the p trunk. A mulch layer two to four inches thick will help keep / down weeds and protect the trunk from lawn mower damage. To avoid crown rot, be sure to keep the mulch away from direct contact with the lower trunk. 0 Stakes can be used if the tree needs support, however, it is S RP best to stake only when necessary as it may result in a weaker / root system. Use strips of fabric or burlap, not wires or ties to secure the stake to the tree. Remove stakes after the first year of growth. • PLANTING NEAR PAD- MOUNTEI) TRANSFORMERS Be sure to allow the correct distance from pad - mounted transformers when planting trees or other vegetation.This diagram shows the minimum distances required when planting near pad - mounted transformers. TIPS FOR SAFE PLANTING AROUND UNDERGROUND TRANSFORMERS: Keep in mind that the transformer must be accessible for service at all times. la Select plants that are easily maintained and suitable for the site. • Allow plants sufficient growing room. • Do not plant in front of the transformer (the side with the padlock). Do not use ground covers as they won't stand up to trampling. Do not allow plantings to overgrow the transformer. • Avoid disposing of liquids through grates on below - ground transformers. At Do not change grade levels around pad- mounted transformers. TREE SELECTION Many of us have a favorite tree. Unfortunately, no one tree is perfect for all locations. Most of our native trees, as well as most commonly used shade trees, can grow to tremendous heights. Because of their great size, they do not fit well in the small spaces of many urban planting locations. These large trees are more likely to conflict with overhead power lines, sidewalks, buildings, and streets. Trees are often planted with little thought as to how large they become once mature. It can be difficult to imagine that the five -or six-foot tree purchased at the nursery will fill a space 80 feet tall and half again as wide. But large - growing tree species will do just that, and well within our lifetime. Sometimes trees are planted with the assumption that they can be pruned to keep them small. This can be very difficult with fast - growing plants, not to mention costly and time consuming. Think about the future: if no one prunes it, will it become a menace? Selecting the right sized trees can reduce and even eliminate the need for future pruning. transformer 1 1 1 1 • • The Pacific Northwest climate supports a great diversity of plants. We can only begin to list all the trees that can be grown in this area. Many more species are available. The following plant list has been prepared to help you select the proper size and species of trees and large shrubs for planting near utility lines or in restricted spaces. In addition to a mature size less than 35 feet tall, these plants were selected for low maintenance, insect and disease resistance, availability, and beauty. The mature sizes listed represent the averages expected for our region. The actual growth of an individual plant will depend on the soil, light exposure, moisture, and temperatures of the site. More information on planting and growing trees and shrubs can be obtained from the references listed at the end of this booklet. Deciduous Trees (20 to 35 feet tall) —These trees can be used where there are over -head lines or other space restrictions. Small trees in the front yard will complement a home without dwarfing it as larger trees can do. When the only planting space available is directly beneath utility lines, trees that mature at 25 feet or less should be used. Fruit Trees —Dwarf varieties should be chosen for apples, pears and cherries. Non dwarf varieties typically are incompatible with power lines as their mature height exceeds 30 feet. The type of root stock these trees are grafted on will affect their size. Consult your local Cooperative Extension or nursery for more information on dwarf trees and recommended varieties. Conifer —These trees are cone - bearing evergreen trees that can be used where there are overhead lines. The trees in this selection will not exceed 30 feet in height at maturity. Shrubs —These shrubs can be used for screen plantings near or beneath utility lines. When enough space is allowed for them to reach their natural width, these shrubs can provide long -term screening without side or top pruning. Hedges— Formal hedges can also be used near or beneath utility lines and provide an excellent screen. Hedges must be pruned annually to maintain their health and vibrancy. Native Plants —These native plants were selected because they grow very well in this region. Native plants are adapted to local climate. Once established, they are more drought tolerant than plants from regions of dissimilar climates. • Acer campestre HEDGE MAPLE Mature size: Approximately 30 feet tall by 30 feet wide. Shape: Dense, rounded canopy. Foliage: Small, deciduous leaves, two to three inches across are dark green in summer and bright yellow in fall. Description: This rugged tree works well in urban conditions. It prefers moist soil but is tolerant of dry, compact soils and air pollution. Plant in full sun to light shade. Pests and disease: No serious insects or diseases but may get aphids, scales or borers. Acer ginnala AMUR MAPLE Mature size: Approximately 20 feet tall by 20 feet wide. Shape: Dense, upright crown and usually grows in multi-stem form. Foliage: Dark, glossy trifoliate deciduous leaves and samaras (seeds) in summer. Leaves turn scarlet red in fall. Description: This hardy deciduous tree grows well in the colder regions of the Northwest. It is easy to transplant and tolerates heat, cold and drought. Plant in full sun to light shade. It is often used as a street tree, in small gardens, on patios, in landscape containers and on screens when branched to the ground. You may also wish to consider a close relative of the Amur Maple, the Rocky Mountain Maple (Acer glabrum). Pests and disease: Fairly insect- resistant. Acer griseum PAPERBARK MAPLE Mature size: Approximately 25 feet tall by 20 feet wide. Shape: Upright spreading, rounded crown. Foliage: Dark green, deciduous, trifoliate leaves. Long lasting red fall color. Description: Its compound leaves provide delicate texture in summer while its peeling, orange -brown to cinnamon -brown bark adds interest year - round. Pests and disease: Maples in general may be susceptible to anthracnose, cankers, leaf spot, leaf scorch, scale insects, caterpillars, aphids or borers. 0 • Acer palmatum JAPANESE MAPLE Mature size: Approximately 25 feet tall by 25 feet wide. It seems to grow wider than it is tall. Shape: Horizontal branching. Foliage: Fine - textured deciduous leaves. Different leaf shapes and colors are available. Green leaves turn orange or deep red in fall. Description: This popular garden tree is often used as a lawn specimen or shrub border. It grows best in filtered shade in rich, well - drained soils. While moderately drought tolerant, it is not well suited to dry, gravelly soils. It should be protected from prevailing winds. Pests and disease: Maples in general may be susceptible to anthracnose, cankers, leaf spot, leaf scorch, scale insects, caterpillars, aphids, borers or verticillium. Amalanchiergrandiflora SERVICEBERRY (also called Shadebush or Juneberry) Mature size: Approximately 20 feet tall by 15 feet wide. Shape: Upright spreading to gracefully spreading. Foliage: Small to medium deciduous green leaves. Bright red to orange -red in fall. Flower: White flowers grow in clusters in April or May. Fruit: Some may bear small, edible, purplish -blue fruit. Description: Good form and strong branching make this an attractive tree. It displays reliable spring bloom and spectacular fall color. Pests and disease: May develop leaf miners. Fire blight and leaf blight also may cause problems. 0 Carpinus japonica JAPANESE HORNBEAM Mature size: Approximately 30 feet tall by 20 to 35 feet wide. Shape: Makes a rounded vase or fan shape when mature. Foliage: Large, sharply- veined leaves often turn red in fall. Flower: Inconspicuous white or yellow flowers. Description: The Japanese Hornbeam grows well in partial shade to full sun. The trunk is showy and the crown is fine textured and dense. Pests and disease: Relatively free of pests and disease but may get cankers. Cercis canadensis EASTERN REDBUI) Mature size: Approximately 35 feet tall by 25 feet wide. Shape: Horizontal branching. Foliage: Rich green, heart- shaped leaves that are three to six inches wide. Yellow fall color. Flower: Deep purple -pink, pea -like flowers appear before the leaves in early spring. Description: The Redbud is a beautiful flowering tree typically used as a lawn specimen, around patios or as a shrub border. Plant in sun to partial shade in moderately moist but well - drained soil. Flower production is typically enhanced after winters with temperatures below freezing. It rarely requires pruning. A close relative, the Judas Tree (Cercis siiiquastrum) also grows well in the Northwest Pests and disease: Leaf spot can be a problem in wet weather. May be susceptible to borers, scale insects, webworm, cankers or verticillium wilt. • Cornus kousa JAPANESE DOGWOOD (also called Korean dogwood) Mature size: Approximately 30 feet tall by 25 feet wide. Shape: Upright when young, broadening to a horizontal branching habit. Foliage: Dense, two to four -inch deciduous leaves may turn deep red in fall. Flower: Large, creamy white blossoms, two to four inches wide, cover leafy branches in June. Fruit: Large raspberry-like fruit ripens late in summer and persists until leaves drop in fall. Description: The Japanese Dogwood is an excellent screen, border or background specimen due to its dense foliage. It enjoys moist, acidic, well - drained soils, and does well in sun or partial shade. Exfoliating bark gives it a mottled gray, tan and brown appearance in winter. Pests and disease: While resistant to anthracnose, it may be susceptible to flower and leaf blight, leaf spot or powdery mildew (in wet weather), summer leaf scorch, borers, crown cankers or cottony scale. Birds are attracted to its fruit. • COMM' mas CORNELIAN CHERRY DOGWOOD Mature size: Approximately 25 feet tall by 20 feet wide. Shape: Multi -stem or single trunk. Foliage: Dark green, pointed -oval leaves turn red or yellow in fall. Flower: Yellow flowers appear along the bare branches in March. Fruit: Edible, scarlet, cherry-like fruit can be used to make preserves. Description: This tree has interesting gray and tan flaking bark and makes a handsome lawn specimen, shrub border or screen when branched to the ground. It should not be used over sidewalks or driveways because of fruit drop. It is best planted in sun to partial shade and can tolerate alkaline soil. Avoid very wet soils. Pests and disease: Birds often eat the fruit, but otherwise this tree is not typically affected by pests or diseases. Occasionally, Dogwoods may develop root rot, leaf scorch, cankers, leaf spot, scale insects or borers. Cotinus coggygria SMOKE TREE Mature size: Approximately 10 feet tall by 15 feet wide. Shape: Upright with rounded habit. Loose, spreading habit often grows wider than it is tall. Foliage: Rounded blue -green leaves turn yellow, red or purple in fall. Flower: Showy flower panicles give the plant its "smoky" appearance from June through September. Description: A rugged plant for use in dry, rocky soils, the Smoke Tree is good for use in shrub borders and is tolerant of many soil types and pH ranges. Plant in full sun in well - drained loam soll. Pests and disease: No serious pests. Some may be afflicted with verticillium wilt, leaf spot or scabs. Crataegus spp. HAWTHORN Mature size: Approximately 30 feet tall by 20 to 25 feet wide. Shape: Broad rounded crown with dense, thorny branches. Foliage: Lustrous dark green leaves range from one to four and one- half inches long depending on the exact species. In the fall, foliage turns orange, scarlet, purple, bronze or copper. Flower: Small white flowers bloom in May or early June. Fruit Bears glossy red one - fourth -inch fruit from fall through winter. Description: The Hawthorn is an outstanding tree for urban planting. It is tolerant of dry soils and is often used as a lawn specimen or in screens. Thorns can be a problem in high traffic areas. Pests and disease: Washington Hawthorns (Crateegus phaeno- pyrum) are less susceptible to insects and disease than other types of Hawthorns. In general, Hawthorns may be susceptible to fireblight, rust, leaf spot, lacebug damage, aphids, cottony cushion scales or borers. Forsythia x intermedia FORSYTHIA Mature size: Eight to 10 feet tall and up to 12 feet wide if not pruned. Shape: Broad - rounded outline. Wide and spreading. Foliage: Small medium to dark green, sharply - serrated, leaves grow all along long, gracefully- arching branchlets. Leaves die off green or with a hint of burgundy. Flower: Showy golden -yellow flowers with four symmetrical petals, one to one and one -half inches long, bloom before leaves unfold in the spring. Description: Forsythia is very adaptable to soils and climates. It succeeds in all but very wet or very dry soils. It can tolerate con- siderable shade, but flowers are most prolific when in full sun. After flowering, it should be sheared to assure the best flowering display the next year. Flower buds may be killed by cold, late winter wind. Pests and disease: Relatively pest free. Hamamelis spp. WITCH HAZEL Mature size: Approximately 15 to 20 feet tall by 15 to 20 feet wide. Shape: Broadly spreading habit. Foliage: Simple alternate leaves that are short- stalked and heart- shaped at the base. Some turn golden yellow in fall and others will turn brownish -red. Flower: Profuse, large, fragrant flowers with golden -yellow petals bloom in fall and winter. Description: Witch Hazel is known for producing an astringent used in the treatment of superficial wounds and cosmetics. It is a popular shrub in gardens and parks due to its fall- winter blooming season. Pests and disease: May be suscestible to leaf gall, aphids or gypsy moths. Laburnum x watereri `Vossii' GOLDEN CHAIN TREE Mature size: Approximately 30 feet tall by 20 feet wide. Shape: Upright branches. Foliage: Leaves become yellow in alkaline soils. Grows best in slightly acid soil. Flower: Striking display of yellow, pea -like flowers in long pendulous clusters in late May. Fruit: All parts of this plant are poisonous. Description: Golden Chain Trees grow best in sun to partial shade and are used as lawn specimens or shrub borders. Plant in well- drained soil with adequate moisture. Pests and disease: Leaf spot, twig blight and aphids may be a problem. • • Maackia amurensis AMUR MAACKIA Mature size: Approximately 20 to 30 feet tall and up to 30 feet wide. Shape: Upright, spreading habit. Foliage: Pointed, one to three -inch oval green leaves grow on branchlets. Fruit Small, dull -white pea -like flower buds grow from the branchlets and bloom in summer. Description: The Amur Maackia is an attractive tree with erect flower clusters. It has shiny amber - colored bark which tends to flake and curl. While it is generally drought- tolerant and can tolerate poor soil conditions, it does best when planted in loose, well- drained soils. Nitrogen - fixing bacteria are associated with its root system, thus it requires little maintenance. Pests and disease: Relatively pest and disease free. Magnolia stellata STAR MAGNOLIA Mature size: Slow growing. Mature trees are up to 20 feet tall by 10 feet wide. Shape: Dense, oval or rounded. Foliage: Dark green leaves are two and one -half to four inches long. Bronze to yellow fall color. Flower: Large, white or pink fragrant flowers bloom in mid -April before leaves develop. Description: The Star Magnolia is an attractive small tree or shrub with fragrant flowers. Avoid planting it in south - facing exposures that can cause early flowering, making flowers susceptible to early rains and late freezes. Pests and disease: While the Star Magnolia is relatively free of insects and disease, it may be susceptible to scale insects, leaf scorch, or iron deficiency. It is not tolerant of root competition or dry soil. Malus spp. CRABAPPLES Mature size: Approximately 25 feet tall by 12 to 20 feet wide. Shape: Open to dense spreading. Foliage: Oval two to -five inch leaves that can be red or green. Often turns yellow in the fall. Flower: Flowers can be white, pink or red, singles or doubles. Fruit: Red, yellow or green, edible fruit. Fruitless varieties are also available. Description: These hearty fruit trees are tolerant of drought and compact soil and require little pruning. They thrive in well - drained soils in full sun. Varieties suggested for planting are the Red Jewel, Snowdrift, and Prairie Fire. Pests and disease: Can be susceptible to apple scab, aphids, mites, fire blight, apple rust, oyster shell scale, tent caterpillars and powdery mildew in the Pacific Northwest. Photiniafraseri PHOTIN.IA Mature size: Approximately 10 to 12 feet tall by 10 feet or wider. Shape: Sometimes grown as a single trunked tree. Foliage: Glossy evergreen leaves, two to five inches long. New growth is bronze -red. Flower: Round, five -inch flower clusters appear in June. Flowers have a slight sweet vanilla scent. Description: Enjoys full sun to partial shade and is fairly drought tolerant. Pests and disease: May get aphids and leaf spot. Root rot can kill these plants in overly wet soil. Myrica californica CALIFORN1A WAXMYRTLE Mature size: Approximately 15 feet tall by 15 feet wide. Shape: Spreading. Foliage: Lustrous narrow evergreen leaves are two to four inches long. Flower: Some trees have white, pink - lavender or purple flowers which grow in upright clusters at the tips of each twig. Flowers bloom typically from April through June. Fruit: Small purple berries appear on female plants in fall and winter. Description: Native to the coastal regions of the Pacific Northwest, .< the California Waxmyrtle enjoys sun to partial shade and is drought tolerant once it is established. Its bark is light brown and smooth when young. Older trees may have flakey outer bark revealing pinkish inner bark or dark patches. Pests and disease: Buds and leaves are favorites of deer and grouse. Prunus spp. FLOWERING CHERRY Mature size: Approximately 20 to 25 feet tall by 20 to 25 feet wide. Shape: Vase shaped to rounded. Foliage: Bronze; green in summer, yellow or red in the fall. Flower: Fragrant pink or white flowers in either singles or doubles. Fruit: Most ornamental varieties are fruitless. Description: Many different dwarf varieties of cherries are available. All are generally valued for their flower, texture of foliage and fall color. Some also have unusual bark. Cherries perform well in landscapes and are moderately drought resistant. To be used as a street tree, a cherry tree should be trained early or grafted on seven -foot standards. Mount Fuji and Kwanzan varieties are suitable for planting near power lines, unlike many larger- growing varieties. Pests and disease: May be susceptible to cankers, scale insects, caterpillars or aphids. • • Prunus spp. FLOWERING PLUM Mature size: Under 25 feet tall. Shape: Rounded habit. Foliage: Dull-green deciduous leaves. Flower. Small white flowers with five equal petals bloom in early spring. Fruit Plums can be sweet or sour, yellow, red or purple. Description: This small tree or shrub is often cultivated for its fruit or as an ornamental plant throughout North America. It thrives best in full sun. The Newport variety is compatible with our climate and is small enough to be safely planted near power lines if necessary. Pests and disease: May be susceptible to scale insects, caterpillars, aphids, borers or cankers. Rhus typhina STAGHORN SUMAC Mature size: Approximately 15 to 25 feet tall. Shape: Loose spreading shrub or scraggly deciduous tree. Foliage: Alternate one to two -inch pinnate leaves composed of long, pointed, separate leaflets. Spectacular scarlet fall color. Flower: Flowers are small in large, showy clusters. Fruit Fruit is crimson color. Description: A large, hardy plant often used for naturalizing, in mass plantings in waste areas, banks or cut areas. It does not make a good specimen tree. Random branching patterns resemble the horns of a male deer. Pests and disease: May be susceptible to rusts, verticillium, leaf spots, aphids or mites, but are usually not seriously affected. Rosa rugosa RAbIANAS ROSE (Saltspray Rose or Sea Tomato) Mature Size: Approximately three to six feet tall, spreading nearly as wide. Shape: Typically a dense, round bush. Foliage: Traditional, glossy, leathery leaves range from dark to light green in color. Some varieties have a crinkled appearance. Leaves of some varieties turn yellow, bronze, orange or reddish in fall. Flower: Produces an abundance of fragrant single or double bloom flowers that are usually two to four inches in diameter and can be white, yellow, red, pink or purple. Fruit: Bright red or orange, tomato- shaped, edible, one -inch rosehips are produced on some varieties. Description: This vigorous rose can be used both as a specimen in the garden or as a screening hedge. It grows well in partial shade to full sun and can tolerate hard freezes, wind, arid, loamy or sandy soils and salt spray. The stems are covered with small thorns. Pests and Disease: Usually very hardy, but may have some problems with aphids, beetles, spider mites, leaf spot, cankers, rust or mildew. Birds may be attracted to the fruit. 0 Sorbus tianshanica RED CASCADE MOUNTAIN ASH Mature size: Approximately 16 feet tall by eight feet wide. Shape: Compact oval. Foliage: Very lustrous green toothed leaflets with pointed tips. Turns yellow -orange in the fall. Flower: Small, white flowers in clusters. Fruit: Small, orange -red fruit grows in clusters and persists into winter unless eaten by birds. Description: This nicely shaped compact tree is ideal for small spaces. Pests and disease: May be susceptible to scale insects, borers or cankers. Stransvaesia davidiana CHINESE STRANSVAESIA Mature size: Six to 20 feet tall by six to 20 feet wide. Foliage: Evergreen leaves are two to four inches long. New leaves are reddish. Flower: White flowers in four -inch clusters appear in June. Fruit: Showy red berries in fall. Description: An attractive shrub for holiday cut foliage, the Chinese Stransvaesia enjoys sun to partial shade in moist, slightly acid soil. It is pollution tolerant. Pests and disease: May be susceptible to fire blight or root rot. Styrax japonicus JAPANESE SNOWBELI. Mature size: Approximately 25 feet tall by 25 feet or more wide. Shape: Rounded to horizontal branching. Foliage: Dark green summer foliage may turn yellow to red in fall. Flower: Small, white flowers hang below upward- pointing leaves along the branches. Blooms in early June. Description: Plant this graceful tree in full sun to partial shade. It does best in a moist, acidic, well - drained organic soil. Pests and disease: Free of pests and disease. • Syringa reticulata JAPANESE TREE LILAC Mature size: Approximately 30 feet tall by 20 to 25 feet or more wide. Shape: Rounded spreading. Foliage: Dark green leaves are two to five inches long. Flower: Mildly fragrant, creamy -white flower clusters appear in mid June. Description: The shiny cherry-like bark adds interest in the winter. The Japanese Tree Lilac enjoys full sun in fairly moist, well - drained soil. Pests and disease: May have problems with bacterial blight, leaf miners, borers or scale. • 0 Syringa vulgaris LILACS Mature size: Approximately eight to 10 feet tall. Shape: Random upright. Foliage: Green heart- shaped leaves. Flower: Sweet - scented plumes bloom in early May. Asian varieties typically bloom later. The classic color is lilac, but selection and cross - breeding have yielded varieties ranging from blue to red to white to yellow. Description: Lilacs are enjoyed for their beautiful sweet- scented flowers. Because they spread vigorously by root suckers, a single shrub can form a spreading thicket. Pests and disease: May by susceptible to spirea aphids, powdery mildew, leaf miners, bacterial blight or scales. Viburnum rhytidophyllum LEATHERLEAF VIBURNUM Mature size: Approximately 15 feet tall by three to 10 feet wide. Shape: Rounded. Foliage: Long, narrow, leathery evergreen leaves are four to 10 inches long. Flower: White flower clusters, four to eight inches across, bloom in spring. Fruit: Scarlet to black fruit in fall. Description: This striking shrub is quite soil tolerant. It prefers sun to shade but can tolerate heavy shade. Pests and disease: Powdery mildew can be a problem. Weigela florida WE I GEIA (also called Old - fashioned weigela) Mature size: Approximately six to 10 feet tall by nine to 12 feet wide. Shape: Densely rounded shrub with coarse, spreading branches that arch to the ground. Foliage: Two to four -inch variegated leaves are a nondescript green. Flower: Profuse red, pink, white or varicolored flowers bloom in late spring to summer, and may continue to bloom sporadically throughout the growing season. Description: Weigela should be pruned lightly after blooming to remove dead branches. It enjoys sun to partial shade and thrives in ordinary, well- drained soli. Pests and disease: May be susceptible to crown gall, blight, leaf spot, nematodes or root rot. • Chamaecyparis obtusa DWARF HINOKI CYPRESS Mature size: Dwarf varieties typically grow up to eight feet tall, but can reach 20 feet in height. Shape: Softly pyramidal to conical. Foliage: Frondlike branchlets give a fernlike appearance in form and texture. Dark green needles have silvery undermarkings. Description: Short ascending branches grow from a buttressed trunk and droop at the tips, ending in flat sprays. The dwarf form of the Hinoki Cypress works well in rock gardens. It enjoys moist, well - drained, acidic soils and full sun to partial shade. Pests and disease: The Hinoki Cypress is relatively free of pests and disease. However, Cypress trees are generally somewhat susceptible to twig and needle blight, leaf browning, leafminers, aphids, spider mites, root rot or bark scales. Pinus aristata BRISTI,ECONE PINE Mature size: A dwarf evergreen tree. It grows to approximately eight to 20 feet in height. Shape: Bushy and conical. Foliage: Long branches are covered with needles that resemble a fox tail. Description: Among the oldest living plants: specimens have been found to be 2,000 to 7,000 years old. Makes an interesting evergreen needle plant for rock gardens or as an accent or specimen. Grows well even in poor, rocky soils, however, is not tolerant of shade or winter winds. Pests and disease: No significant pests or disease. Pines in general may be susceptible to blight, needle cast, nematodes, pine wilt, spider mites, air pollution, wooly aphids, scale, rust, sawfly larvae, moths, weevils or gall rust. Pinus densiflora `Umbraculifera' DWARF JAPANESE RED PINE (Also called .Dwarf Tanyosho Pine) Mature size: Approximately 10 to 20 feet tall. Shape: When young, these trees grow with a crooked or leaning habit. With time, the habit becomes more vase - shaped, with wide, spreading upward - arching branches. Foliage: Plumes of rich green, three to five -inch evergreen needles grow in twos. Description: This hardy species has exquisite decorative red - brown or orange -brown bark. It can be used as a specimen or in groupings. It is quite heat tolerant, but needs well - drained soil. Pests and disease: Pines in general may be susceptible to blight, needle cast, nematodes, pine wilt, spider mites, air pollution, wooly aphids, scale, rust, sawfly larvae, moths, weevils or gall rust. • • 0 Taxus baccatta Stricta' UPRIGHT IRISH YEW Mature size: Approximately 20 feet tall by five feet wide. Slow growing. Shape: Bushy and conical with a dense crown and multi- pointed top. Foliage: Very dense growth of golden yellow evergreen needles. Fruit: Male and female flowers are carried on different trees. Male flowers are globular, grow singly in the axils of the leaves and shed pollen in February. Female flowers are small and green. Fruit Female plants bear small, red, fleshy fruits with highly poisonous seeds. Description: Widely grown as a hedge in gardens, the Upright Irish Yew is long -lived, tolerant of heavy pruning and is generally a low maintenance plant. Fairly drought tolerant. Once it is established it enjoys sun to shade. Often used as a screen or shrub border. Pests and disease: Yews in general may be susceptible to root rot or taxus weevils. Thuja occidentalis Pyramidalis' PYRAMIDALIS Mature size: Approximately five to 10 feet tall but can grow up to 40 feet tall. Shape: Strongly fluted and buttressed at the base with a narrow compact pyramidal crown. Foliage: Leaves are scale -like, overlapping and grow in branchlets. They are typically bright green above and yellow -green below. Flower: Winter buds are tiny and may be covered in scales. Description: This shrub tolerates very alkaline soil. It prefers sandy soil rather than moist or clay soils. It's reddish -brown bark is ridged and fissured lengthwise and can be pulled off in long fibrous strips. This shrub is often used for ornamental hedges. Pests and disease: May be susceptible to blight, cankers or root rot. • • a i 8 PLANT SELECTION INDEX 1 V A Common name (Scientific name) * * * N g o a Amur Maackia (Maackia amurensis) W ✓ ✓ 12 Amur Maple (Acer ginnala) R ✓ ✓ 7 Bristlecone Pine (Pinus aristata) ✓ ✓ 17 California Waxmyrtle (Myrica californica) ✓ ✓ ✓ 13 Chinese Stransvaesia ( Stransvaesia davidiana) W R ✓ 15 Cornelian Cherry Dogwood (Corpus mas) Y Y ✓ ✓ 10 Crabapples (Malus spp) V Y ✓ ✓ 12 Dwarf Hinoki Cypress (Chamaecyparis obtusa) ✓ ✓ ✓ 17 Dwarf Japanese Red Pine (Pines densifbm `Umbraculife a) ✓ 1 17 Eastem Redbud (Cercis canadensis) P Y ✓ ✓ 9 Flowering Cherry ( Prunus spp) V Y/R ✓ ✓ 13 Flowering Plum (Prunus spp) W 0/R 1 ✓ 14 Forsythia (Forsythia x intermedia) Y ✓ ✓ ✓ 11 Hawthorn (Crataegus spp) W V ✓ ✓ 10 Hedge Maple (Acer campestre) Y ✓ ✓ 7 Golden Chain Tree (Laburnum x watereri `Vossii') Y ✓ 1 11 Japanese Dogwood ( Cornus kousa) W Y/R ✓ ✓ 9 Japanese Hornbeam (Carpinus japonica) R / ✓ 8 Japanese Maple (Acer palmatum) V 0/R ✓ ✓ 8 Japanese Snowbell (Styrax japonicus) W Y/R ✓ ✓ 15 Japanese Tree filar (Syringa reticulates) W W ✓ ✓ 15 Leatherleaf Viburnum (Viburnum rhytidophy&um) W ✓ ✓ 16 Lilacs (Syringa vulgaris) V V 1 1 ✓ 16 PaperbarkMaple (Acer griseum) R ✓ ✓ 7 ................. ............................................................................................................................................................................................................ ............................... Photinia ( Photinia fraseri) R ✓ ✓ ✓ 13 Pyramidalis (T'huja occidentalis) ✓ ✓ ✓ 18 Ramanas Rose (Rosa rugosa) V V V ✓ ✓ 14 Red Cascade Mountain Ash (Sorbus tianshanica) W Y Y/0 ✓ ✓ 15 Serviceberry (Amalanchier xglandiflora) /P 0/R ✓ 8 Smoke Tree (Cotinus coggygria) Y/R ✓ ✓ 10 Staghorn Sumac (Rhos typhina) R ✓ ✓ 14 Star Magnolia (Magnolia stellata) /P Y ✓ ✓ 12 Upright Irish Yew (Taxus bacatta `Stricta) ✓ ✓ ✓ 18 Weigela ( Weigela florida) V ..._ ..... _..V ✓ ✓ ✓ 16 Witch Hazel (Hamamelis x intermedia) Y/R V ✓ ✓ 11 *V=varied color; P =pink; R =red; Y= yellow; W= white, 0 =orange • 1 'Native plant species • are well adapted to our environment and generally require less maintenance in comparison to non-native plant species once established. Here are some native trees and shrubs you may wish to consider. NATIVE PLANT SELECTION INDEX Common name (kientzfic name) Blue Elderberry (Sambucus caerulea) Evergeen Hucklebery (Yaccinium ovatum) Gooseberry (Ribes bbbii) Hardhack (Spiraea doughsit) Hookers Willow (Salix hookeriana) Indian Plum (Osmaronia cerasifirmis) Kinnildnnik (Arctostapbylos uva-ursi) Mock Orange (Philadep bus Oceanspray (Holodiscus discolor) Oregon Grape (Mabonia spp.) Pine-mat Manzanita (Artostapbylos nevadensis) Red Flowering Current (Ribes sanguineum) Red-osier Dogwood (Cornus stolonifera) Salal (andtheria sballon) Scouler's Willow (Salix scouleriana) Snowberry (Symphoricalpos mollis var besperius) Swamp Birch (Betula glandulosa) Vine maple (Acer circunatum) Western Azalea (Rbododendrun occidentale) Western Serviceberty (Amalancbier alnifolia) Wild Rose (Rosa nutkana) EROSION CONTROL 1 1 1 1 1 1 1 1 1 GROUND COVER 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 V7 '07/P IV V W R V V VR *V=varied color; P=pink; R=red; Y=yellow; W=white Plants listed in this index are not detailed in the previous section of this guide. 1 • LONG- TERM TREE CARE Long term tree care is essential to ensure the health and vitality of your plant. Four components of long term -tree care are: pruning, fertilization, irrigation and pest control. Pruning— Pruning is an essential operation for the growth and well -being of landscape plants. The health of the tree is improved or maintained by removing dead, diseased, and damaged wood. The quality and quantity of flowers and fruit are increased with proper pruning. Here is the general procedure for pruning trees: 1. Remove dead, diseased, and damaged wood. 2. Remove or head back branches that are crossing other branches or growing in the wrong direction. 3. Thin, as necessary, to allow light and air into the center of the tree and for even spacing of branches. When a pruning cut is made, the wound should be as small as possible. Before a branch is to be removed, locate the branch collar: the small fold of bark at the base of a branch where it joins the trunk. Make your cut just outside of this ridge. Cutting into the collar increases the wound size and the possibility of decay. To remove a large branch, undercut it first to avoid tearing the bark. (See diagram below.) A. Make the first cut (ctrr A) on the under- side of the branch, slightly out from the branch collar. B. Remove the entire branch with the second full cut (cur B) from the top outside the undercut. C. Remove the remaining stub by the third cut (ctrr c) at the edge of the collar. NOTE: Recent research indicates that applying a wound dressing to the cut area is not necessary and may, in some cases, prove detrimental to the tree. 1 • Fertilization —A tree that has adequate mineral elements is healthier, stronger, more tolerant of stress and more aesthetically pleasing. If the fertility level of the soil is low, then the appropriate addition of fertilizer will benefit the plant. Consult your local nursery, Cooperative Extension or the U.S. Soil Conservation Service for soil test laboratories in your area. Indications of low fertility are: unusually slow growth overall poor tree health poor leaf color Deciding when to fertilize will depend upon the nutrients needed, application method, climate, and soil conditions. The most common application times are in late spring, when the plants have come out of dormancy, and in late fall when the plants enter dormancy. Irrigation— Insufficient water during the growing season may not kill a plant immediately, but drought stress makes trees more susceptible to insect, disease and environmental problems in subsequent years. Drought and water rationing, two current concerns, contribute to a drought- stressed plant. There are two ways to reduce summer irrigation while avoiding drought stress. At Plant species adapted to the local weather pattern to reduce the need for summer irrigation. Remove the turf surrounding the tree and mulch that area to reduce competition for water from surrounding turf. Place two to four inches of mulch around the base of the tree to hold in moisture lost to evaporation. However, make sure to leave about three inches of space between mulch and the trunk to avoid trunk rot. Water infrequently but to a depth of eight to twelve inches. Whenever irrigation occurs, it is essential to water deeply and thoroughly. Frequent, shallow watering encourages shallow roots that are less likely to survive stressed conditions. Pest control — Contact your local Cooperative Extension for recommendations regarding pest control specifiics to your tree species. Information regarding possible pests and diseases is included in the descriptions of trees in this guide. • • • Aaamr. maackia 20-30 feet tall Flowering cherry 2.5-25 feet tall Cornelia cherry dogwood 25,feet tall 1225 • 3/99 • 5000 green river vicinity critical areas puget sound energy geoeningeers