**Bangor Hydro-Electric Company**

> **Northeast Reliability Interconnect**
>
> **Post-Construction\
> Vegetation Maintenance Plan**

***Prepared for:***

**Bangor Hydro-Electric Company**

**P.O. Box 932**

**Bangor, Maine 04402-0932**

***Prepared by:***

**TRC Environmental Corporation**

**400 Southborough Drive**

**South Portland, Maine 04106**

**May 2005**

![](media/image1.jpeg){width="1.4895833333333333in"
height="1.0104166666666667in"}

**1.0** **INTRODUCTION [1-1](#introduction)**

2.0 TYPICAL ROW VEGETATION MAINTENANCE PROCEDURES
[2-1](#typical-row-vegetation-maintenance-procedures)

2.1 Mechanical Techniques [2-2](#mechanical-techniques)

2.2 Use of Herbicides [2-4](#use-of-herbicides)

3.0 VEGETATION MAINTENANCE WITHIN STANDARD waterbody BUFFERS
[3-1](#vegetation-maintenance-within-standard-waterbody-buffers)

3.1 Additional Vegetation Maintenance Restrictions Within Standard
Waterbody Buffers
[3-1](#additional-vegetation-maintenance-restrictions-within-standard-waterbody-buffers)

4.0 VEGETATION MAINTENANCE WITHIN SALMON STREAM BUFFERS
[4-1](#vegetation-maintenance-within-salmon-stream-buffers)

4.1 Salmon Habitat Stream Buffers [4-1](#salmon-habitat-stream-buffers)

4.1.1 Additional Vegetation Maintenance Restrictions Within Salmon
Habitat Stream Buffers
[4-2](#additional-vegetation-maintenance-restrictions-within-salmon-habitat-stream-buffers)

4.2 Modified Salmon Stream Buffers
[4-3](#modified-salmon-stream-buffers)

5.0 VEGETATION MAINTENANCE WITHIN Designated WADING BIRD AND WATERFOWL
HABITAT
[5-1](#vegetation-maintenance-within-designated-wading-bird-and-waterfowl-habitat)

6.0 VEGETATION MAINTENANCE AT rare PLANT and unique natural area
LOCATIONs
[6-1](#vegetation-maintenance-at-rare-plant-and-unique-natural-area-locations)

6.1 Rare Plant Species [6-1](#rare-plant-species)

6.2 Unique Natural Areas [6-1](#unique-natural-areas)

7.0 MAINTENANCE PROCEDURES FOR osprey NESTS
[7-1](#maintenance-procedures-for-osprey-nests)

7.1 Guidelines for Removal of Osprey Nests Along the NRI ROW
[7-1](#guidelines-for-removal-of-osprey-nests-along-the-nri-row)

8.0 MAINTENANCE PROCEDURES WITHIN VISUAL SCREENs
[8-1](#maintenance-procedures-within-visual-screens)

8.1 The Narraguagus and Machias River Visual Screens
[8-1](#the-narraguagus-and-machias-river-visual-screens)

8.2 The St. Croix River Visual Screen
[8-2](#the-st.-croix-river-visual-screen)

9.0 SYSTEM FOR LOCATING/MARKING RESTRICTED AREAS
[9-1](#system-for-locatingmarking-restricted-areas)

10.0 TRAINING OF MAINTENANCE PERSONNEL
[10-1](#training-of-maintenance-personnel)

10.1 Personnel and Schedule [10-1](#personnel-and-schedule)

10.2 Content of Training Sessions [10-1](#content-of-training-sessions)

TABLES

1\. Waterbody Crossing Table [3-3](#__RefHeading___Toc102797176)

2\. Designated Salmon Habitat Streams
[4-1](#__RefHeading___Toc102797177)

3\. Wading Bird and Waterfowl Habitats^1^
[5-1](#__RefHeading___Toc102797178)

4\. Rare Plant and Unique Natural Area Locations
[6-2](#__RefHeading___Toc102797179)

5\. NRI Visual Screen Locations [8-2](#__RefHeading___Toc102797180)

FIGURES

1\. TYPICAL ROW VEG MAINTENANCE [2-3](#__RefHeading___Toc102614404)

2\. SALMON STREAM VEG MAINTENANCE PRIOR TO PERIODIC MAINTENANCE
[4-4](#__RefHeading___Toc102614405)

3\. ALMON STREAM VEG MAINTENANCE FOLLOWING PERIODIC MAINTENANCE
[4-5](#__RefHeading___Toc102614406)

# INTRODUCTION

Bangor Hydro-Electric Company (BHE) has prepared this Northeast
Reliability Interconnect Post-Construction Vegetation Maintenance Plan
(Vegetation Maintenance Plan) to be a stand-alone document containing
all restrictive maintenance requirements for natural resources and
visual screening along the Northeast Reliability Interconnect (NRI)
right-of-way (ROW), and to ensure that the specified resources are
properly identified in the field and protected accordingly. The
requirements set forth in the Vegetation Maintenance Plan, as proposed
by BHE and incorporated in federal, state and local permits for the NRI
project, apply to routine maintenance along the NRI ROW and are not
intended to apply to emergency maintenance and repair actions.

Throughout construction, numerous construction techniques and impact
mitigation measures and restrictions were implemented to minimize
potential adverse effects on natural resources. To continue that effort,
the goal of the Vegetation Maintenance Plan is to supply BHE maintenance
personnel and contractors with a single, cohesive set of vegetation
maintenance specifications for the NRI ROW. BHE personnel or their
designated representatives will ensure that these specifications are
followed by regularly inspecting all work and requiring corrective steps
to be taken where necessary. The Vegetation Maintenance Plan is intended
to be used in conjunction with the project as-built Plan and Profile
drawings to locate the areas where maintenance restrictions apply.

The natural resources subject to restrictive maintenance requirements
include:

-   wetlands and waterbodies;

-   designated rivers or streams that contain endangered Atlantic salmon
    habitat or are located within associated watersheds;

-   designated waterfowl and wading bird habitats (WWH);

-   areas that contain rare plant populations and identified unique
    natural communities; and

-   osprey nests that are built on transmission line structures.

In addition, a visual screen of vegetation will be maintained at the
Narraguagus and Machias River crossings and on the U.S. side of the St.
Croix River crossing in which vegetation maintenance activities will be
limited.

The remainder of the Vegetation Maintenance Plan is organized as
follows:

-   Section 2.0 summarizes the typical vegetation maintenance methods
    and procedures that will be utilized by BHE along the NRI ROW;

-   Section 3.0 describes the additional vegetation maintenance
    requirements and restrictions associated with all waterbodies
    crossed by the NRI ROW. Section 3.0 also includes a waterbody table
    to aid in locating these resources in the field;

-   Section 4.0 provides the additional vegetation cutting restrictions
    that pertain to nine designated salmon habitat streams and
    identifies those streams and their locations. This section also
    identifies restrictions for vegetation maintenance within the
    waterbody buffers at streams within the Narraguagus, Machias and
    East Machias River watersheds;

-   Section 5.0 provides the vegetation maintenance restriction that
    pertains to designated WWH and identifies the locations of those
    areas;

-   Section 6.0 describes the maintenance procedures to be followed in
    the vicinity of three rare plant species and one unique natural
    community;

-   Section 7.0 provides the procedures to be used for managing or
    removing osprey nests that are built on power line structures;

-   Section 8.0 includes a description and vegetation maintenance
    restrictions that will be applied for the vegetated visual screens
    to be established along the Narraguagus, Machias and St. Croix
    Rivers;

-   Section 9.0 describes the system to be used for identifying
    restricted areas in the field while performing maintenance
    activities; and

-   Section 10.0 summarizes the training requirements for BHE's ROW
    maintenance personnel and contractors.

In locations where individual restrictions or procedures overlap and/or
multiple restrictions apply, the more stringent restrictions and all
applicable procedures will be followed by BHE maintenance personnel and
contractors.

# TYPICAL ROW VEGETATION MAINTENANCE PROCEDURES

Routine vegetation maintenance of the NRI ROW is required to comply with
the New England Power Pool (NEPOOL) Vegetation Maintenance Standards
(NEPOOL Vegetation Maintenance Standard), to maintain the integrity and
functionality of the line, to maintain access in case of emergency
repairs and to facilitate safety inspections. The objective of BHE\'s
ROW management will therefore be to control large woody vegetative
growth to ensure the integrity and safe operation of the transmission
line. This will be accomplished by practicing Integrated Vegetation
Management (IVM) which utilizes a combination of hand cutting and
selective herbicide applications. Mechanical mowing is used only in
unusual circumstances to regain control of vegetation, should the
typical procedures not be sufficient.

To minimize any negative environmental impacts, vegetation will remain
in place to the extent practicable. The removal of large trees was done
during initial ROW preparation prior to construction of a new line.
Follow-up maintenance activities during operation of the line require
only the selective removal of "capable species," dead or "danger trees."
Capable species are defined as those plant species that are capable of
growing tall enough to reach within the required clearance between the
conductors and vegetation established by the NEPOOL Vegetation
Maintenance Standard. The NEPOOL Vegetation Maintenance Standard for a
345 kV transmission line requires that a minimum of 15 feet of
separation be maintained between vegetation and the conductors (ref.:
*NEPOOL Operating Procedure No. 3- Transmission Maintenance Scheduling
for Facilities Operating at 115 KV and Above (OP 3), Appendix D*,
approved by the NEPOOL Participants Committee on May 3, 2002). Due to
the sag in the height above ground of electric transmission lines
between poles, which varies with the distance between poles, tension on
the wire, electrical load, air temperature and other changing
conditions, the required NEPOOL clearance is typically achieved by
removing all capable species and topping other vegetation greater than 8
to 10 feet tall.

Once the vegetation in an area is brought under control (usually three
to four years following construction), these practices will generally be
carried out on four or five-year maintenance cycles depending on growth,
weather, geographic location, and corridor width. Significant branches
that overhang the ROW and any dead or damaged trees outside of the ROW
that could contact the power lines or come within 15 feet of a conductor
("danger trees") may be removed as soon as they are identified. This is
the manner in which vegetation height will typically be maintained along
the NRI ROW, except in waterbody and visual buffer zones (see Sections
3.0, 4.0 and 8.0) and at rare plant or unique natural community
locations (Section 6.0). Figure 1 illustrates the results of typical
vegetation clearing and maintenance to comply with the NEPOOL Vegetation
Maintenance Standard.

The following procedures will be implemented during all vegetation
maintenance activities to ensure protection of sensitive natural
resources:

-   All areas of significant soil disturbance will be stabilized and
    revegetated immediately following completion of maintenance activity
    in the area;

-   Equipment access through wetlands or over waterbodies will be
    avoided as much as practicable by utilizing existing public or
    private access roads, with landowner approval where required;

-   Equipment will not drive through waterbodies even if the waterbody
    is dry. Construction mats or other methods will be used to span
    waterbodies;

-   Construction mats or equivalent for equipment support will be used
    if saturated soils are present; and

-   Rutting or significant damage to wetland or waterbody bank
    vegetation, if any, will be repaired immediately following
    completion of maintenance activities in the area.

## Mechanical Techniques

During routine vegetation maintenance after construction, the mechanical
means of maintaining the height of vegetation on the ROW consists
primarily of hand cutting, with limited use of motorized equipment in
areas that are directly accessible from public or private access roads
or from a vegetated access way established in the middle of the ROW
during initial clearing within 75-foot wide waterbody buffer zones.

[]{#__RefHeading___Toc102614404 .anchor}FIGURE 1. TYPICAL ROW VEG
MAINTENANCE

The procedure will be to cut all capable species and any dead or danger
trees at ground level and top other vegetation greater than 8 to 10 feet
tall, except in waterbody or visual buffer zones and at rare plant and
unique natural community locations. All vegetation cut during routine
maintenance is cleaned up or otherwise handled in accordance with the
Maine Slash Law.

## Use of Herbicides

BHE\'s herbicide application program will be consistent with most New
England utilities and is used in conjunction with the mechanical methods
of vegetation maintenance. It consists of directional spraying targeted
species along the ROW by hand with a low-volume foliar application. In
addition, herbicides may be applied to cut stumps and surfaces of larger
trees. The use of selective herbicides control only the targeted woody
vegetation, while leaving low-growing plant communities consisting of
grasses, forbs and shrubs to thrive. Aerial application will not be
used. Only herbicides with low toxicity to non-target plants and
animals, and that are registered with and approved by the U.S.
Environmental Protection Agency (EPA-approved) will be used.

Typically, the ROW will receive herbicide treatment the year following
construction and then again two to three years following that to gain
control of vegetation growth. Once control is achieved, treatment
occurs, as needed, on the standard four to five year cycle. By utilizing
selective herbicides, the ROW will eventually become a dense,
low-growing plant community, which impedes woody vegetation from being
established; hence there are fewer woody species to treat in future
applications.

The following procedures will be implemented during all vegetation
maintenance activities utilizing herbicides:

-   Herbicides will be used in strict accordance with the manufacturer's
    EPA-approved labeling and will not be applied directly to water or
    areas where surface water is present;

-   Herbicides will not be applied, mixed, transferred or stored within
    waterbody buffers or applied within 25 feet of wetlands that have
    water present at the surface;

-   Herbicides will not be mixed, transferred or stored within the 50
    feet of waterbodies with 25 foot buffers, within 75 feet of
    waterbodies with 75 foot buffers, and within 50 feet of wetlands
    that have water present at the surface;

-   Herbicides will not be applied, mixed, transferred or stored within
    50 feet of known rare plant species or identified unique natural
    communities, within 100 feet of any known well or spring, or within
    100 feet of a home or other human dwelling;

-   Herbicides will not be applied to any area when it is raining;

-   The foreman of every crew using herbicides will be licensed by the
    Maine Board of Pesticides Control (MBPC) and will remain in eye
    contact with all persons on his/her crew applying herbicides. At
    least one individual from any company applying herbicides for BHE
    must also hold a Commercial Master License issued by the MBPC and
    must be in Maine during any application. Application of pesticides
    will be in accordance with applicable regulations promulgated under
    the Maine Pesticides Control Act, including those regulations to
    minimize drift, to maintain setbacks from sensitive areas
    (residential/recreational areas and schools) during application, and
    to maintain setbacks from surface waters during the
    storing/mixing/loading of herbicides;

-   The chemicals are typically mixed in a truck-mounted tank that stays
    on the access roads. The application is done by personnel with
    backpacks who travel along the ROW by all terrain vehicle and spot
    treat target species; and

-   Each target tree is sprayed until the foliage is covered with little
    or no run-off.

As mentioned previously, application of herbicides is prohibited within
25 feet of wetlands that have water present at the surface. The location
of all wetlands and other important natural resources crossed by the NRI
ROW will be shown on the as-built Plan and Profile drawings. The
presence of water on the surface will be determined prior to herbicide
use in any wetland. Tables identifying the locations of other resources
where herbicide application is prohibited are provided in the following
sections.

# VEGETATION MAINTENANCE WITHIN STANDARD waterbody BUFFERS

A minimum 25-foot buffer, as measured from the top of bank on each side,
will be established for all waterbodies crossed by the NRI ROW between
the Orrington Substation up to and including Blackman Stream. A 75-foot
buffer, as measured from the top of bank on each side, will be
established for all waterbodies crossed by the NRI ROW between Blackman
Stream up to and including the St. Croix River. Special procedures and
restricted activities will apply within these waterbody buffers during
construction and follow-up vegetation maintenance. Vegetation
maintenance within waterbody buffers is typically conducted on a three
or four year cycle, depending on growth and vegetation. This section
describes the restrictions related to vegetation cutting and maintenance
that will apply within all standard waterbody buffers. Additional
restrictions apply in designated salmon stream buffers and within the
visual screens at the Narraguagus, Machias and St. Croix Rivers, as
described in Sections 4.0 and 8.0, respectively. Table 1, provided at
the end of this section, includes the names and locations of all
waterbodies crossed by the NRI ROW. The location of all waterbodies
crossed by the NRI ROW will also be shown on the as-built Plan and
Profile drawings.

It is important to note that the applicable vegetation maintenance
procedures and restrictions that apply to typical ROW maintenance
(Section 2.0) also apply within the standard waterbody buffers. The
applicable procedures and restrictions include the MBPC restrictions,
restoring and stabilizing disturbed soils, disposition of slash in
accordance with the Maine Slash Law, ROW access, the restrictions on
waterbody crossings by equipment within the ROW, and the use of
construction mats and other procedures related to work in wetlands.

## Additional Vegetation Maintenance Restrictions Within Standard Waterbody Buffers

The following additional restrictions apply to vegetation maintenance
within standard waterbody buffers.

-   Prior to construction and during vegetation maintenance after
    construction, only capable species greater than 8-10 feet tall will
    be removed. No other vegetation, other than dead or danger trees,
    will be removed;

-   Removal of capable species, dead or danger trees will be by hand
    cutting or reaching into the buffer zone with tree harvesting
    equipment located outside the zone, or from an access way
    established in the middle of the ROW during initial clearing within
    75-foot wide waterbody buffer zones;

-   No herbicides will be used, stored, mixed or transferred between
    containers within the buffer areas; and

-   No refueling or maintenance of equipment, including chain saws, will
    occur within the buffer areas.

The additional restrictions on vegetation maintenance within waterbody
buffers will allow for taller vegetation within riparian buffers to
provide additional shading of streams and reduce the warming effect of
direct sunlight (insolation). Low ground cover will also remain to
filter sediment in surface runoff. As a result, the buffers will
continue to function in a similar manner as before construction. The
restrictions are also intended to minimize ground disturbance and ensure
that herbicides or petroleum products are not able to reach the
waterbody via surface runoff or groundwater.

Figure 1 also illustrates vegetation clearing and maintenance practice
within standard waterbody buffer zones.

[]{#__RefHeading___Toc102797176 .anchor}TABLE 1. WATERBODY CROSSING
TABLE

INSERT FOLLOWING CONSTRUCTION

# VEGETATION MAINTENANCE WITHIN SALMON STREAM BUFFERS

The Atlantic Salmon Commission (ASC) has identified nine rivers or
streams crossed by the NRI ROW as containing salmon habitat or potential
habitat for salmon.

## Salmon Habitat Stream Buffers

The nine "salmon habitat streams," or "waters of special environmental
concern" as identified by the ASC, are listed on Table 2. The location
of all waterbodies crossed by the NRI ROW, including salmon streams,
will also be shown on the as-built Plan and Profile drawings.

  --------------------------------- ------------ ---------- ------------- -------------------- ---------- ------------- --------------------
  []{#__RefHeading___Toc102797177                                                                                       
  .anchor}Table 2. Designated                                                                                           
  Salmon Habitat Streams                                                                                                

  **Name**                          **NRI        **Begin    **Distance    **Direction^2,3^**   **End Ref. **Distance    **Direction^2,3^**
                                    Station      Ref. Pole  (ft)^2,3^**                        Pole       (ft)^2,3^**   
                                    No.^1,2^**   No.^2^**                                      No.^2^**                 

  Narraguagus River                                                                                                     

  Tributary to Fifth Machias Lake                                                                                       

  Tributary to Fifth Machias Lake                                                                                       

  Tributary to Fletcher Brook                                                                                           

  Machias River                                                                                                         

  Dead Stream                                                                                                           

  Lanpher Brook                                                                                                         

  Huntley Brook                                                                                                         

  Joe Brook                                                                                                             

  ^1^NRI station number of stream                                                                                       
  centerline.\                                                                                                          
  ^2^To be incorporated following                                                                                       
  construction.\                                                                                                        
  ^3^Distance and direction from                                                                                        
  reference pole to beginning or                                                                                        
  ending edge of salmon stream                                                                                          
  buffer.                                                                                                               
  --------------------------------- ------------ ---------- ------------- -------------------- ---------- ------------- --------------------

The waterbody buffers along these streams will be subject to additional
maintenance restrictions to enhance the shading of these waterbodies to
the maximum extent allowed by the NEPOOL Vegetation Maintenance
Standard. Vegetation maintenance near the salmon habitat streams will be
subject to the same procedures and prohibitions, as applicable, that are
required on the typical ROW and for standard stream buffers, namely:
MBPC requirements, restoring and stabilizing disturbed soils,
disposition of slash, ROW access constraints, the restrictions on stream
crossings by equipment within the ROW, the use of construction mats and
other procedures related to work in wetlands, the restricted use of
mechanized tree harvesting equipment, and the prohibition on the use,
mixing, or transfer of herbicides and petroleum products within the
buffer zone.

### Additional Vegetation Maintenance Restrictions Within Salmon Habitat Stream Buffers

The following additional restrictions apply to vegetation maintenance
within salmon stream buffers.

Only those trees capable of growing to a height within 15 feet of a
conductor within the next 3 to 4 years will be topped or removed. No
other vegetation other than dead or danger trees will be removed; and

Topping of trees is the preferred method of vegetation maintenance,
unless the tree is dead or dying, or topping will leave insufficient
vegetation to sustain the tree.

Except at the Machias and Narraguagus River crossings, structure
locations were sited as close to the edge of the salmon stream buffers
as possible to create a conductor height that will allow for higher
vegetation requiring minimal trimming. The closer the structure is to
the stream the higher the conductor will be over the stream and the
taller the vegetation. This will result in taller buffers that provide
maximum shading (and cooling) of the salmon habitat streams. In one
instance, at a tributary to Fletcher Brook (project survey station
2913+02), structures could not be located near the edge of the buffers,
so taller structures were used.

Structures will be located further back from the Machias and Narraguagus
Rivers to minimize the visual impact from these high value recreational
resources and designated Outstanding River Segments (see Section 8.1).
Fisheries resource agencies were consulted and are in agreement that the
trade-off between maximizing the visual buffer as opposed to achieving
maximum shading is justified at these two crossings due to the presence
of existing, adjacent open habitat. Maintaining the maximum allowable
vegetation height at the NRI ROW crossings at these locations would do
little to improve or maintain existing water temperatures.

Figures 2 and 3 illustrate vegetation clearing and maintenance practices
within salmon stream buffer zones.

## Modified Salmon Stream Buffers

BHE will apply the salmon habitat stream buffer clearing and maintenance
restrictions described above at all streams located in the Narraguagus,
Machias and East Machias River watersheds. Accordingly, within these
waterbody buffers only those trees capable of growing to a height within
15 feet of the conductors in the next 3 to 4 years will be topped or
removed (in addition to any dead or danger trees). The potential for
additional vegetation height along these steams should minimize
potential warming that might otherwise result from maintaining adjacent
vegetation at 8-10 feet tall. Watershed boundaries and identification of
perennial versus intermittent streams are shown on Table 1: Waterbodies
Crossed by the NRI Project, provided in Section 3.0.

[]{#__RefHeading___Toc102614405 .anchor}FIGURE 2. SALMON STREAM VEG
MAINTENANCE PRIOR TO PERIODIC MAINTENANCE

[]{#__RefHeading___Toc102614406 .anchor}FIGURE 3. ALMON STREAM VEG
MAINTENANCE FOLLOWING PERIODIC MAINTENANCE

# VEGETATION MAINTENANCE WITHIN Designated WADING BIRD AND WATERFOWL HABITAT 

In addition to other applicable maintenance requirements, vegetation
maintenance activity using motorized equipment within moderate and high
value WWH will be prohibited between April 15 and July 15 each year to
minimize the potential disruption of avian breeding and nesting
activity. Hand cutting (without chain saws) is allowed.

Table 3 lists the identification and location information for the
designated moderate and high value WWH subject to the April 15 to July
15 restriction. These WWH areas will also be shown on the as-built Plan
and Profile drawings.

  -------------------------------------------------------------------------------------------------------------------------------------------------
  []{#__RefHeading___Toc102797178                                                                                                
  .anchor}Table 3. Wading Bird and                                                                                               
  Waterfowl Habitats^1^                                                                                                          
  --------------------------------- ----------- ----------- ------------ ------------------ ----------- ----------- ------------ ------------------
  **WWH ID No., Town**              **Begin NRI **Begin     **Distance   **Direction^2^**   **End NRI   **End Ref.  **Distance   **Direction^2^**
                                    Station No. Ref. Pole   (ft)^2^**                       Station No. Pole        (ft)^2^**    
                                    ^2^**       No.^2^**                                    ^2^**       No.^2^**                 

  13641/ 050340, Brewer                                                                                                          

  13433, Holden                                                                                                                  

  13060, Eddington                                                                                                               

  12718, Bradley                                                                                                                 

  12642, Bradley                                                                                                                 

  12445/ 110241, Bradley                                                                                                         

  12239/ 110269, Bradley                                                                                                         

  12028, Bradley                                                                                                                 

  12061, Bradley                                                                                                                 

  12089, Milford                                                                                                                 

  12043,\                                                                                                                        
  T32 MD                                                                                                                         

  11795,\                                                                                                                        
  T32 MD                                                                                                                         

  11892,\                                                                                                                        
  T32 MD                                                                                                                         

  11679/ 111104,\                                                                                                                
  T32 MD                                                                                                                         

  11679/ 111104,\                                                                                                                
  T32 MD                                                                                                                         

  11679/ 111104,\                                                                                                                
  T32 MD                                                                                                                         

  11679/ 111104,\                                                                                                                
  T32 MD                                                                                                                         

  11682,\                                                                                                                        
  T32 MD                                                                                                                         

  11569,\                                                                                                                        
  T34 MD                                                                                                                         

  11569,\                                                                                                                        
  T34 MD                                                                                                                         

  11569,\                                                                                                                        
  T34 MD                                                                                                                         

  11569,\                                                                                                                        
  T35 MD                                                                                                                         

  11569,\                                                                                                                        
  T35 MD                                                                                                                         

  11569,\                                                                                                                        
  T35 MD                                                                                                                         

  11569,\                                                                                                                        
  T35 MD                                                                                                                         

  11658,\                                                                                                                        
  T35 MD                                                                                                                         

  11541,\                                                                                                                        
  T35 MD                                                                                                                         

  11093,\                                                                                                                        
  T35 MD                                                                                                                         

  11238,\                                                                                                                        
  T36 MD BPP/T37 MD BPP                                                                                                          

  11256,\                                                                                                                        
  T36 MD                                                                                                                         

  11238,\                                                                                                                        
  T37 MD                                                                                                                         

  IMBIV02100\*079\*ME,\             []{.mark}   []{.mark}   []{.mark}    []{.mark}          []{.mark}   []{.mark}   []{.mark}    []{.mark}
  T37 MD                                                                                                                         

  10517, No. 21 TWP                                                                                                              

  9996/999, Princeton                                                                                                            

  9881, Princeton                                                                                                                

  9792, Princeton                                                                                                                

  9803, Princeton                                                                                                                

  9765, Princeton                                                                                                                

  ^1^No vegetation maintenance                                                                                                   
  using motorized equipment between                                                                                              
  April 15 and July 15.\                                                                                                         
  ^2^To be incorporated following                                                                                                
  construction.                                                                                                                  
  -------------------------------------------------------------------------------------------------------------------------------------------------

# VEGETATION MAINTENANCE AT rare PLANT and unique natural area LOCATIONs

## Rare Plant Species

Three state-listed rare plant species occur along the NRI ROW. Two of
these species, showy lady's slipper (*Cypripedium reginae*) and sheathed
sedge (*Carex vaginata*) occur in the same area of the ROW in a northern
white cedar swamp at the south end of the Sawtelle Heath in Baileyville.
Showy lady's slipper is a threatened species in Maine and the sheathed
sedge is currently listed as a species of special concern. (A
representative of the Maine Natural Areas Program stated that sheathed
sedge will likely be down-listed in the near future.) Initial clearing
of the area surrounding these two species will be done during the winter
with at least six inches of snow cover. Additionally, all tree species,
except young northern white cedar (*Thuja occidentalis*) up to eight
feet tall, will be removed. Vegetation maintenance in this area during
operation will consist of hand cutting all trees other than northern
white cedar that is less than 8-10 feet tall. The northern white cedar
will be topped when it reaches that height. No herbicide use will be
allowed within 50 feet of this area and all cut, woody debris will be
removed from the ROW to ensure that plants are not smothered.

The third rare species, alga-like pondweed (*Potamogeton confervoides*)
is an aquatic species of special concern found in Allen Brook. Because
this species is found only in the water, no travel through the water is
allowed, and no herbicide use and only hand cutting of vegetation is
allowed within the stream buffer; hence, no special maintenance
restrictions will apply for this species.

## Unique Natural Areas

A small area east of Burnt Land Lake is characterized as a Blueberry
Lichen Barren, a community type that is considered to be rare in Maine.
The NRI crosses a short section of the Blueberry Lichen Barren
immediately adjacent to Stud Mill Road. Vegetation maintenance in this
area during operation will consist of hand cutting all capable species
and topping other vegetation that is greater than 8-10 feet tall. No
herbicide use will be allowed within 50 feet of this area.

Table 4 summarizes the locations and special restrictions associated
with the rare plant species and the Blueberry Lichen Barren.

  --------------------------------- ---------- ---------- ------------ ------------------ ---------- ---------- ------------ ------------------
  []{#__RefHeading___Toc102797179                                                                                            
  .anchor}Table 4. Rare Plant and                                                                                            
  Unique Natural Area Locations                                                                                              

  **Name, Town**                    **Begin    **Begin    **Distance   **Direction^1^**   **End NRI  **End Ref. **Distance   **Direction^1^**
                                    NRI        Ref. Pole  (ft)^1^**                       Station    Pole       (ft)^1^**    
                                    Station    No.^1^**                                   No.^1^**   No.^1^**                
                                    No.^1^**                                                                                 

  Showy lady's slipper,                                                                                                      
  Baileyville^2^                                                                                                             

  Sheathed sedge, Baileyville^2^                                                                                             

  Alga-like pondweed, Allen Brook,                                                                                           
  T35 MD3                                                                                                                    

  Blueberry Lichen Barren, T35                                                                                               
  MD^4^                                                                                                                      

  ^1^To be incorporated following                                                                                            
  construction.\                                                                                                             
  ^2^Remove all trees except                                                                                                 
  northern white cedar less than                                                                                             
  8-10 feet tall. Hand cutting                                                                                               
  only. No herbicide use within 50                                                                                           
  feet.\                                                                                                                     
  ^3^Follow waterbody buffer                                                                                                 
  restrictions.\                                                                                                             
  ^4^No herbicide use within 50                                                                                              
  feet.                                                                                                                      
  --------------------------------- ---------- ---------- ------------ ------------------ ---------- ---------- ------------ ------------------

The location of the rare plant populations and Blueberry Lichen Barren
will be shown on the as-built Plan and Profile drawings.

# MAINTENANCE PROCEDURES FOR osprey NESTS

It is common for osprey to nest on the top of power line structures.
Typically, nests are allowed to remain in place unless there is a chance
they are going to come into contact with the conductor. Osprey use nests
from year to year, and build up the nests annually. Sometimes the nests
get so large they can touch a conductor, or be close enough to create an
arc. If there is a risk of arcing or conductor contact, BHE will follow
its existing guidelines for removing nests, which usually takes place in
the fall of the year. No permit is required.

## Guidelines for Removal of Osprey Nests Along the NRI ROW

The following process will be completed for any removal of an osprey
nest that is built on the NRI ROW:

-   Only inactive nests will be taken. Nests that contain eggs or chicks
    will not be disturbed;

-   Nests will only be taken between September 1 and April 15, and only
    if birds are not actively using the nest;

-   Nests will be relocated to nesting platforms, when possible,
    otherwise they will be destroyed when they are removed;

-   BHE Environmental Services will be notified of the date, number of
    nests moved or destroyed, and the town where the nest(s) are/were
    located. Environmental Services will keep an updated, running total
    of nests moved or destroyed. The list of nests removed will be
    distributed to the line supervisors periodically. Environmental
    Services will evaluate what steps may need to be taken if more than
    20 nests require action in one year; and

-   Environmental Services will submit an annual report of all osprey
    nests moved or removed by BHE to the Maine Department of Inland
    Fisheries and Wildlife.

# MAINTENANCE PROCEDURES WITHIN VISUAL SCREENs

Typical ROW vegetation practices will be restricted within the three
vegetated visual screens or buffers established along the NRI ROW. The
three locations are at the crossings of the Narraguagus and Machias
Rivers in T34 MD and T37 MD BPP, respectively, and at the St. Croix
River in Baileyville.

## The Narraguagus and Machias River Visual Screens

Because the Narraguagus and Machias Rivers are high value recreational
resources and designated Outstanding River Segments, the maximum,
practicable vegetated visual screen will be maintained across the ROW at
each side of these crossings. During design, structures were sited well
away from the river banks to minimize their visual impact. The width of
the visual buffer areas is based on the site-specific structure
locations, topography and existing vegetation type to provide the most
effective visual screening of the power line as possible, within the
constraints of the NEPOOL Vegetation Maintenance Standard and reasonable
construction and maintenance requirements. The salmon stream buffer
vegetation clearing and maintenance restrictions will be followed
because both rivers are designated salmon habitat streams. To provide
maximum visual screening, no cutting of vegetation will be allowed in
these visual buffer areas, except as required to comply with the NEPOOL
Vegetation Maintenance Standard.

The visual buffer area at the Narraguagus River extends all the way to
the nearest structures on either side of the river; approximately 290
feet from the water's edge on the west side, and approximately 500 feet
from the water on the east side. The visual buffer area at the Machias
River extends to the topographic high points on either side of the
river; approximately 210 feet from the water's edge on the west side,
and approximately 360 feet from the water on the east side.

The other applicable restrictions, such as no use of herbicides or
petroleum products near waterbodies and wetlands, will also apply.

## The St. Croix River Visual Screen

A vegetated visual screen will be maintained across the ROW along the
U.S. side of the St. Croix River crossing because this is an important
recreational resource. Structures will be placed well-away from the
river bank. Within the waterbody buffer at the St. Croix River, the
existing forest cover will be maintained to the maximum extent allowed
by the NEPOOL Vegetation Maintenance Standard. Only those trees capable
of growing to a height within 15 feet of the conductors within the next
3 to 4 years will be topped or removed. No other vegetation, other than
dead or danger trees, will be removed.

A summary table of visual screen locations is provided in Table 5,
below. The location of the visual screens at all three rivers will also
be included on the as-built Plan and Profile drawings.

  --------------------------------- ---------- ---------- ------------ ------------------ ---------- ------------ ------------------
  []{#__RefHeading___Toc102797180                                                                                 
  .anchor}Table 5. NRI Visual                                                                                     
  Screen Locations                                                                                                

  **Name**                          **NRI      **Begin    **Distance   **Direction^1^**   **End Ref. **Distance   **Direction^1^**
                                    Station    Ref. Pole  (ft)^1^**                       Pole       (ft)^1^**    
                                    No.^1^**   No.^1^**                                   No.^1^**                

  Narraguagus River^2^                                                                                            

  Machias River^2^                                                                                                

  St. Croix River^2^                                                                      Ends at                 
                                                                                          the river               

  ^1^To be incorporated following                                                                                 
  construction.\                                                                                                  
  ^2^No cutting of vegetation                                                                                     
  allowed within this visual                                                                                      
  screen, except topping or removal                                                                               
  of all trees expected to grow                                                                                   
  within 15 feet of a conductor                                                                                   
  within the next 3-4 years.                                                                                      
  Herbicide use prohibited within                                                                                 
  riparian buffer area.                                                                                           
  --------------------------------- ---------- ---------- ------------ ------------------ ---------- ------------ ------------------

# SYSTEM FOR LOCATING/MARKING RESTRICTED AREAS

BHE has in place a system for locating specific areas or features in the
field by maintaining a database that references a variety of sensitive
areas to the nearest structure (pole) or road location. In some
instances, signage is attached to the structures. Using structure
identification numbers has proven to be the most effective. Therefore,
all structures along the NRI transmission line will be numbered at the
time of construction. The numbers will be included on the as-built Plan
and Profile drawings. BHE's sensitive area database will be updated to
include all such sensitive areas along the NRI ROW and their locations
relative to the nearest structure. That data will then be incorporated
in this Vegetation Maintenance Plan.

All protected resources, buffer areas and other areas where maintenance
restrictions apply will be located in this manner. The distance and
direction from the nearest structure to the sensitive area will be
included beside the name of the area and the structure number.
Maintenance contractors working on the ROW will be given the Vegetation
Maintenance Plan prior to receiving the required environmental training
(Section 10.0). Use of the Vegetation Maintenance Plan in conjunction
with the NRI as-built Plan and Profile drawings (also provided) will
enable maintenance contractors to locate restricted areas in the field.

# TRAINING OF MAINTENANCE PERSONNEL

This section summarizes the environmental training that will be required
for all personnel with maintenance responsibilities on the ROW.

## Personnel and Schedule

All BHE personnel and contractors who will be participating in
vegetation maintenance activities on the ROW will receive appropriate
environmental training before he/she is allowed access to the ROW. The
level of training will be commensurate with the type of duties of the
personnel. The training will be given prior to the start of maintenance
activities. Replacement or new employees that did not receive the
initial training will receive similar training prior to performing any
maintenance activities on the ROW.

## Content of Training Sessions

Prior to receiving maintenance training, each participant will receive a
copy of this Post-Construction Vegetation Maintenance Plan and be
instructed to read the entire Plan before the scheduled training
session. The training session will then consist of a review of all
protected resources and restricted areas, the respective maintenance
requirements and restrictions for each, and a review of how these areas
and resources can be located in the field (relative to the nearest
numbered structure). Training will include familiarization with and use
of the as-built Plan and Profile drawings in conjunction with the
contents of the Vegetation Maintenance Plan, as well as basic causes and
preventive and remedial measures for contamination, erosion and
sedimentation of water resources. Training will also include safety,
monitoring, and reporting requirements.