CHAPTER 1.0 PROPOSED ACTION AND PURPOSE AND...

Preliminary EA for Utility Right-of-Way 1-1 December 2014

Herbicide Treatment Project on FS National Forests Chapter 1 – Proposed Action and Purpose and Need

CHAPTER 1.0 PROPOSED ACTION AND PURPOSE AND NEED

1.1 INTRODUCTION

The United States Forest Service (FS), Arizona Public Service Company (APS), and Salt River Project

Agricultural Improvement and Power District (SRP) are responsible for the management of vegetation

within utility corridors in Arizona. The FS administers approximately 12.1 million acres of land within

the state of Arizona, and APS and SRP (collectively the Utilities) have approximately 3,082 miles of

existing electrical distribution and transmission lines crossing FS System Lands within the Apache-

Sitgreaves (ASNF), Coconino (CNF), Kaibab (KNF), Prescott (PNF) and Tonto (TNF) National Forests

in Arizona (excluding the Coronado National Forest) (Table 1-1; Figure 1-1 through Figure 1-6).

Table 1-1 Miles of Line and Acres of Right-of-Way by National Forest within

Forest Service System Lands in Arizona

Field Office Miles Acres

APS SRP APS SRP

Apache-Sitgreaves 161 32 2,536 1,068

Coconino 453 0 3,755 0

Kaibab 261 0 3,504 0

Prescott 1,398 0 4,343 0

Tonto 462 315 6,675 5,333

Subtotal 2,735 347 20,813 6,401

Total 3,082 27,214

The Utilities must manage vegetation near their transmission and distribution lines to provide a safe and

reliable supply of electricity and to prevent blackouts, power outages, and wildfires which can harm

people, wildlife, habitat, and property. The Utilities are committed to implementing the best integrated

vegetation management (IVM) solution utilizing industry accepted best management practices (American

National Standards Institute [ANSI] A300, Part 7, ISA 2014) and maintain compliance with the North

American Electric Reliability Corporation (NERC) Reliability Standard FAC-003 standard.1 Current IVM

solutions being implemented by the Utilities on the FS-managed lands within Arizona include mechanical

treatments using heavy machinery equipped with industrial masticators and manual treatments such as

hand cutting. To further address vegetation management within the rights-of-way, the FS and the Utilities

have agreed to consider the use of herbicides for select treatment of undesirable vegetation within the

Utilities’ authorized rights-of-way and prepare an Environmental Assessment (EA) analyzing that

potential action.

Vegetation interference with transmission and distribution power lines is one of the most common causes

of electrical outages throughout the United States. Electric power outages may occur when trees or tree

limbs grow, fall, or make contact with electric overhead power lines. Outages can occur when overhead

lines stretch or sag onto trees due to increased load or changes in ambient conditions, such as high air

1 http://www.nerc.com/pa/Stand/Project%20200707%20Transmission%20Vegetation%20Management/FAC-003-

2_White_Paper_2009Sept9.pdf

http://www.nerc.com/pa/Stand/Project%20200707%20Transmission%20Vegetation%20Management/FAC-003-2_White_Paper_2009Sept9.pdf

http://www.nerc.com/pa/Stand/Project%20200707%20Transmission%20Vegetation%20Management/FAC-003-2_White_Paper_2009Sept9.pdf



Figure 1-1 Transmission and Distribution Lines on Forest Service System Lands



Figure 1-2 Transmission and Distribution Lines on Apache-Sitgreaves National Forest



Figure 1-3 Transmission and Distribution Lines on Coconino National Forest



Figure 1-4 Transmission and Distribution Lines on Kaibab National Forest



Figure 1-5 Transmission and Distribution Lines on Prescott National Forest



Figure 1-6 Transmission and Distribution Lines on Tonto National Forest



temperature or high wind speed. Since 1996, the presence of vegetation within electrical rights-of-way

has been implicated in initiating three large-scale electric grid failures in the United States and Canada,

including the massive August 14, 2003, blackout that affected 50,000,000 people.

Vegetation in contact with or flashover with power lines can start fires. Flashover can occur when any

part of a bare high-voltage line gets too close to vegetation. If flashover does occur between a branch and

high-voltage line, there is the possibility that the branch could ignite and fall to the ground. If flammable

material is present on the ground, it could cause a fire. Properly maintained vegetation within utility

rights-of-way can act as effective firebreaks for the control and suppression of wildfire. In Arizona, the

2012 Gladiator Fire, which burned 16,000 acres and forced the evacuation of the Town of Crown King,

was attributed to vegetation interference with power lines.

Recognizing the importance of reliable electric service in the Energy Policy Act of 2005 (P.L. 109-58,

enacted August 8, 2005, section 1211), Congress made provisions for electric system reliability standards,

including vegetation management (NERC Reliability Standard FAC-003-3). Congress specified that

Federal land management agencies responsible for approving rights-of-way for electric transmission or

distribution facilities located on Federal lands within the U.S. must expedite any approvals necessary to

allow the owners or operators of such facilities to comply with reliability standards that pertain to

vegetation management, electric service restoration, or resolution of situations that imminently endanger

the reliability or safety of the facilities.

The Utility Vegetation Management and Bulk Electric Reliability Report from the Federal Energy

Regulatory Commission (FERC), September 7, 2004, recognized the importance of vegetative

management for the safety and reliability of electric transmission.2 Executive Order 13212, 66 Federal

Register 28357 (May 18, 2001), directs executive departments and agencies to take appropriate actions, to

the extent consistent with applicable laws, to expedite projects or review of permits in order to improve

the production, transmission, and conservation of energy while maintaining safety, public health, and

environmental protection.3

Section 302(b) of the Federal Land Policy and Management Act of 1976 directs the FS to “take any

action necessary to prevent unnecessary or undue degradation of the [public] lands” (43 United States

Code [USC] 1732).4 The regulations for implementing the National Forest Management Act of 1976

(36 CFR Part 219.27 a.3.) also provide direction for management of public lands.5 Supplementing this

mandate is Section 2(b)(2) of the Public Rangelands Improvement Act of 1978 in which Congress

reaffirms a national policy and commitment to “manage, maintain, and improve the condition of public

rangelands” (43 USC 1711).6

2 http://www.ferc.gov/industries/electric/indus-act/reliability/veg-mgmt-rpt-final.pdf

3 http://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/Executive_Order_13212.pdf

4 http://www.blm.gov/flpma/FLPMA.pdf

5 http://www.gpo.gov/fdsys/pkg/CFR-2003-title36-vol2/pdf/CFR-2003-title36-vol2-part219-subpartA.pdf

6 http://www.gpo.gov/fdsys/pkg/STATUTE-92/pdf/STATUTE-92-Pg1803.pdf

http://www.ferc.gov/industries/electric/indus-act/reliability/veg-mgmt-rpt-final.pdf

http://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/Executive_Order_13212.pdf

http://www.blm.gov/flpma/FLPMA.pdf

http://www.gpo.gov/fdsys/pkg/CFR-2003-title36-vol2/pdf/CFR-2003-title36-vol2-part219-subpartA.pdf

http://www.gpo.gov/fdsys/pkg/STATUTE-92/pdf/STATUTE-92-Pg1803.pdf



In response to the threats of wildfire, the President and Congress have directed the United States

Department of Agriculture (USDA) FS, through implementation of the National Fire Plan (United States

Department of the Interior [USDI] and USDA Forest Service 2001a)7, and the Healthy Forests

Restoration Act of 20038, to take more aggressive actions to reduce catastrophic wildfire risk on public

lands. The actions would be taken to protect life and property, and to manage vegetation in a manner that

provides for long-term economic sustainability of local communities, improved habitat and vegetation

conditions for fish and wildlife, and other public land uses. Maintenance of rights-of-way vegetation

reduces risk to the wildland-urban interface and fulfills objectives of the National Fire Plan (USDI and

USDA Forest Service 2001a) and the Healthy Forests Restoration Act of 2003.

On June 29, 2007, the BLM published the Programmatic Environmental Impact Statement (PEIS) Final

Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States.9

The PEIS analyzed the effects of using herbicides for treating vegetation on public lands in the western

United States. The BLM’s PEIS (2007) for herbicide use provides a broad, comprehensive background

source of information which subsequent environmental analyses can be tiered (40 CFR 1502.20),

including other agencies such as FS (See Section 1.5 for more information).

For the pesticides commonly used by the FS in its management activities, Human Health and Ecological

Risk Assessments (HERAs) are prepared. In these documents, the process of risk assessment is used to

quantitatively evaluate the probability (i.e. risk) that a pesticide use might pose harm to humans or other

species in the environment. The FS incorporates relevant information from the HERA into environmental

assessment documents prepared for pesticide projects, which are used to guide decision-making and to

disclose to the public potential environmental effects. The Utilities are proposing to only use herbicides

that are approved for use in Arizona and for which a risk assessment for the chemical in question has been

prepared and approved.

When the FS approves the construction of an electric transmission or distribution line, it is a long-term

commitment of the area in the permitted rights-of-way. This includes a commitment to allow continuous

operation and maintenance of the facilities. Although the FS authorizations are not exclusive, subsequent

uses within the rights-of-way must be compatible with the permitted rights-of-way. The electrical facility

must routinely be maintained and be able to operate unimpeded for its intended purpose through its full

range of anticipated and designed conditions. On FS land, rights-of-way are established through a permit

process called a Permit Authorization or Easement that allows the utilities to conduct maintenance-related

activities within an established right-of-way. Under the permit process, the Utilities are authorized to

work within the established rights-of-way corridors to maintain their infrastructure and manage

vegetation.

The Utilities manage vegetation within the permitted rights-of-way to (1) reduce the risk of wildfires and

outages that may result when vegetation comes into contact with or cause a flashover with transmission

7 http://www.forestsandrangelands.gov/resources/reports/documents/2001/8-20-en.pdf

8 http://www.gpo.gov/fdsys/granule/STATUTE-117/STATUTE-117-Pg1887/content-detail.html

9 http://www.blm.gov/wo/st/en/prog/more/veg_eis.html

http://www.forestsandrangelands.gov/resources/reports/documents/2001/8-20-en.pdf

http://www.gpo.gov/fdsys/granule/STATUTE-117/STATUTE-117-Pg1887/content-detail.html

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html



and distribution lines, (2) ensure the transmission and distribution lines are managed to maximize the

opportunity for those lines to survive wildfires, (3) ensure public health and safety and the safety of

electrical workers, (4) ensure access, and (5) protect environmental resources.

The Utilities currently maintain vegetation in their rights-of-way on FS System Lands in Arizona through

mechanical and manual methods. These methods consist of both hand cutting with chain saws, hand saws,

and axes, and the use of heavy machinery equipped with industrial masticators. The current maintenance

methods are consistent with industry standards, regulations, and recommendations including:

ANSI A300 Standards for Tree Care Operations: Tree Shrub, and other Woody Plant

Maintenance (ANSI A300 Part 1 – 2008; ANSI A300 Part 7 –2006)

ANSI Z133.1 Standard for Tree Care Operations: Pruning, Trimming, Repairing, Maintaining,

and Removing Trees and Cutting Brush – Safety Requirements (ANSI Z133.1 2012)

Occupational Safety and Health Administration (OSHA) 1910.269 Regulations for Electric

Power Generation, Transmission, and Distribution (29 CFR 1910.269)

International Society of Arboriculture (ISA) Best Management Practices Utility Pruning of Trees

(ISA 2004)

ISA Best Management Practices: Integrated Vegetation Management, second edition (2014).

Utility Arborist Association Best Management Practices: Field Guide to Closed Chain of Custody

for Herbicides in the Utility Vegetation Management Industry (2011)

National Wildland-Urban Interface Code (ANSI 2012)

National Electrical Safety Code (NESC 2007)

Federal Energy Regulatory Commission (FERC) Mandatory Reliability Standards, Uniform Fire

Code (2012).

1.2 PROPOSED ACTION

The proposed action is to authorize the Utilities to use herbicides to manage vegetation as part of utility

vegetation management activities within established rights-of-way on FS System Lands in Arizona in

accordance with existing Permit Authorizations or Easements for the lines. The Utilities would continue

using non-herbicide treatment methods on a project-by-project basis to manage lands within rights-of-way

in accordance with established FS policies and procedures, and as authorized under existing Special Use

Permits or Easements for the rights-of-way. Herbicide applications would be consistent with National

Forest Land and Resource Management Plans for the ASNF (USDA 1987a)10

, CNF (USDA 1987b)11

,

KNF (USDA 2014)12

, PNF (USDA 1986)13

, and TNF (USDA 1985)14

. Although the proposed action is

10 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev7_019948.pdf

11http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5420011.pdf

12 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3791580.pdf

13 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5122089.pdf

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev7_019948.pdf

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5420011.pdf

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3791580.pdf

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5122089.pdf



externally generated by the Utilities, it is considered to be supportive of FS objectives set forth in the

National Fire Plan (USDI and USDA Forest Service 2001a) and the Healthy Forests Restoration Act of

2003.

Aerial application of herbicides is not proposed.

1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION

The purpose of this proposed project is to authorize the Utilities to use selected herbicides for the

treatment of undesirable vegetation within existing power line rights-of-way within the ASNF, CNF,

KNF, PNF, and TNF in Arizona. If authorized, herbicides would be used in combination with existing

vegetation management methods (manual and mechanical) and become part of the Utilities’ IVM

approach. The need for the proposed action is to add an additional and beneficial tool (use of herbicides)

to existing vegetation management practices that reduce the risk of electrical outages and fire ignition

caused by vegetation interference with transmission and distribution power lines and protects facilities

from damage due to wildfires. To successfully meet these requirements, the Utilities must implement

vegetation treatments to prevent wildfires, power outages, and injury to life or property. Maintenance of

right-of-way vegetation also fulfills objectives of the National Fire Plan (USDI and USDA Forest

Service 2001a) and the Healthy Forests Restoration Act of 2003.

Adding herbicide application to existing practices reduces the frequency, duration, and cost of vegetation

management when compared to manual and mechanical methods alone. Herbicide treatment in

combination with current manual and mechanical vegetation management methods can be an effective,

economical, and environmentally sound method to maintain vegetation within the Utility rights-of-way.

1.4 DECISION TO BE MADE

The forest supervisors of the ASNF, CNF, KNF, PNF, and TNF are the responsible officials for this

proposal. Based on the information, data, and analysis included in the EA, the forest supervisor will do

one of the following:

Determine if significant environmental effects would result from implementing the proposed

selected use of herbicides, which would require the preparation of an Environmental Impact

Statement.

Determine if the proposed action, using selected herbicides to manage undesirable vegetation, has

acceptable environmental consequences that, individually or cumulatively, are not considered to

be significant.

Determine not to allow the use of herbicides for vegetation management.

The completed EA will provide the responsible official with the basis upon which to make an informed

decision. The decision will outline the requirements necessary to authorize the proposed use of herbicides

to manage vegetation within the Utilities’ rights-of-way. Forest supervisors are responsible for reviewing

14 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3795286.pdf

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3795286.pdf



and approving or disapproving the herbicides proposed for use in the annual treatment plans and

consequent Pesticide Use Proposals (PUPs) submitted to the FS for the use of herbicides to manage

vegetation.

1.5 DOCUMENTS THAT INFLUENCE THE SCOPE OF THE EA AND ARE

INCORPORATED BY REFERENCE

Regulations to implement the National Environmental Policy Act provide for the reduction of bulk and

redundancy (40 CFR 1502.21) through incorporation by reference when the effect will reduce the size of

the document without impeding agency and public review of the action. The BLM’s PEIS (2007) for

herbicide use provides a broad, comprehensive background source of information which subsequent

environmental analyses can be tiered (40 CFR 1502.20), including other agencies like the FS. In January

2005, the FS published the Final Environmental Impact Statement for Integrated Treatment of Noxious or

Invasive Weeds, which analyzed the effects of using herbicides for treating vegetation within the CNF,

KNF, and PNF15

. In addition to the FEIS from 2005, the FS and Federal Highway Administration also

published Environmental Assessment for Management of Noxious Weeds and Hazardous Vegetation on

Public Roads on National Forest System Lands in Arizona (2003).16

This EA, along with other FS NEPA

documents such as Environmental Analysis for the Implementation of the Apache-Sitgreaves National

Forests Integrated Forest-wide Noxious or Invasive Weed Management Program (2008)17

and

Environmental Assessment for Integrated Treatment of Noxious or Invasive Plants, Tonto National Forest

(2012)18

, analyzed the effects of using herbicides for treating vegetation within National Forest Lands in

Arizona. Tiering allows local offices to prepare more specific environmental documents without

duplicating relevant portions of the PEIS.

This Herbicide EA will tier from the PEIS (BLM 2007), EIS (FS 2005), and EAs (FS 2003, 2008, and

2012) and will define the use of herbicides within the Utility rights-of-way on FS System Lands in

Arizona.

1.6 SCOPING AND PUBLIC PARTICIPATION

To be determined through coordination with FS

1.6.1 Issues

Through the internal and external scoping process, several issues were identified: [Or in internal scoping

only: Through internal scoping held on XXXX, 2014, several issues were identified:]

15http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/30_FSPLT1_0

13753.pdf

16 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_020955.pdf

17http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/4995_FSPLT2

_029014.pdf

18http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/4482_FSPLT2

_284237.pdf

http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/30_FSPLT1_013753.pdf


http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_020955.pdf







List issues

Appendix A contains a summary of the internal scoping process, along with the issues considered and

dismissed from further analysis.


Herbicide Treatment Project on FS National Forests Chapter 2 – Alternatives

CHAPTER 2.0 ALTERNATIVES 1

2.1 INTRODUCTION 2

This chapter describes and compares the alternatives considered for the herbicide treatment proposal to 3

manage vegetation within the Utility rights-of-way within the ASNF, CNF, KNF, PNF, and TNF in 4

Arizona. It includes a description of each alternative considered and the appropriate design features and 5

mitigation measures. We present the alternatives in comparative form, defining the differences between 6

each alternative and providing a clear basis for choice among options by the decision maker and the 7

public. Some of the information used to compare the alternatives is based upon the design of the 8

alternative and some of the information is based upon the environmental, social, and economic effects of 9

implementing each alternative. 10

2.2 ALTERNATIVE CONSIDERED IN DETAIL 11

To be determined through alternative development with FS. Two alternatives are described (1) No Action 12

and (2) Utility Proposed Alternative. 13

2.2.1 Alternative 1: No Action 14

Under the No Action Alternative, the Utilities would continue to maintain their current infrastructure and 15

rights-of-way, as defined under existing authorizations and other agreements. The management approach 16

to controlling vegetation, ensuring access, and maintaining equipment is largely cyclical. Under the 17

existing authorizations, the Utilities manage vegetation that poses a risk of an impending risk to the 18

infrastructure. These risks are identified during regularly scheduled annual line patrols. 19

No action would be taken to use herbicides to treat vegetation within rights-of-way on FS System Lands 20

in Arizona. Under this alternative, the Utilities would continue to manage lands within rights-of-way in 21

accordance with established FS policies and vegetation management procedures. The Utilities currently 22

use a variety of manual and mechanical methods to manage vegetation within rights-of-way throughout 23

Arizona. Those methods can be costly, occur on a more frequent basis, and because they often require the 24

use of more staff and heavy equipment and trucks, may result in more significant impacts to 25

environmental resources. 26

Prior to vegetation treatments, the Utilities coordinate with the FS for environmental compliance and 27

permitting. These treatments are completed on a project-by-project basis in accordance with existing 28

Special Use Permits or Easements for the rights-of-way. These activities would continue if the No Action 29

Alternative were selected. 30

2.2.2 Alternative 2: Utility Proposed Alternative 31

The FS proposes to authorize the Utilities to use herbicides to manage vegetation as part of utility 32

vegetation management activities within established rights-of-way on FS System Lands in Arizona in 33

accordance with existing Permit Authorizations or Easements for the lines. This alternative would involve 34

the ground application of United States Environmental Protection Agency (EPA) and United States 35

Department of Agriculture (USDA)-approved herbicides through the use of sprayers and other ground 36

equipment. There would be no aerial application of herbicides. Herbicide treatments would occur in 37



selected locations within established utility line rights-of-way where vegetation was cleared during line 1

construction and continuously maintained through an existing non-herbicide treatment program. Under 2

this alternative, the Utilities would continue using non-herbicide treatment methods in combination with 3

herbicide application methods. Herbicide application methods would abide by established FS policies and 4

procedures, which are authorized under existing Special Use Permits or Easements for the rights-of-way. 5

2.2.2.1 Herbicide Treatment Methods 6

Herbicide treatments would follow FS procedures outlined in FS Manual 2150 Pesticide-Use 7

Management and Coordination. Herbicides would be applied according to the current label directions. 8

The Utilities would comply with changes in label directions that may occur in the future and state 9

registration requirements. 10

Herbicides would be used to control specific types of vegetation. Two treatment methods are included: 11

1. Selective right-of-way application: Herbicides are used to treat undesirable vegetation whose 12

physiology is such that it could potentially impact the reliability of the line, the associated 13

facilities (e.g., towers, guy wires, etc.), or pose a fire fuel load concern. Herbicides are applied to 14

re-growth and seedling vegetation along rights-of-way that have been cleared to utility and 15

industry standards using manual and mechanical methods in accordance with existing permit 16

authorizations and easements for the lines. 17

2. Non-selective combustible free space treatment: Combustible free space provides a fire break, 18

reduces the risk of fire ignition, and protects utility wood pole structures during a fire event under or 19

near the power lines. This treatment does not apply to the large high voltage transmission towers 20

usually found on 345 or 500 kilovolts (kV) power lines. Herbicides would be used to create a 21

combustible free space in a minimum of a 10-foot radius around distribution and transmission poles 22

with equipment and hardware types that have a history of becoming an ignition source. Examples of 23

equipment found on subject poles include transformers, capacitor banks, and switches. Only about 24

8 percent of the poles in the transmission and distribution system have equipment where the 25

combustible free space treatment is needed. This treatment is required by the International Code 26

Council’s 2012 International Wildland Interface Code Section A102.3.1. In addition, the combustible 27

free space treatment may be used on any transmission or distribution wood pole, particularly in high 28

fire risk areas, such as forested areas with steep terrain. 29

Selective herbicide treatments of utility rights-of-way would occur on a routine schedule based on the 30

clearance needs for an individual line. Frequency of herbicide treatment differs depending on factors such 31

as vegetation type, reintroduction of incompatible vegetation, location of the line, the clearance standard, 32

and company practices. Following initial and follow-up applications, routine herbicide treatments would 33

occur cyclically based on regrowth of treated vegetation. 34



2.2.2.2 Application of Herbicides 1

The Proposed Action Alternative includes use of only herbicides approved by the EPA and USDA, which 2

would be applied with these standard ground application techniques: 3

1. Foliar application 4

2. Hack and squirt application 5

3. Cut stump treatment 6

4. Combustible free space treatment 7

The foliar application methods are designed for the treatment of vegetation foliage that is less than 10 feet 8

tall within the utility rights-of-way. Foliar application methods include application through the use of 9

sprayers and other ground equipment using existing access roads and routes. There would be no aerial 10

application of herbicides. Prior to implementing herbicide treatments within rights-of-way, specific 11

application methods for individual herbicide projects will be determined during review of PUPs that the 12

Utilities submit to the agency for approval. 13

The hack and squirt method could be used as a selective treatment for larger woody vegetation that is 14

unsuitable for foliar application. Brush or trees three inches in diameter or greater are typically more 15

effectively managed by this method. Once these large woody stems are identified, the tree is cut using a 16

sharp knife, saw, or ax, or drilled with a power drill or other device. Herbicide is then immediately 17

applied to the cut with a backpack sprayer, squirt bottle, syringe, or similar equipment. The herbicide 18

mixture is applied at an approximate ratio of 1 cubic centimeter (cc) per one-inch diameter of stem (i.e., a 19

4-inch stem would be treated around the cut ring with approximately 4 cc of mixture) to prevent regrowth. 20

The Utilities do not anticipate using the hack and squirt method on a regular basis, but this method could 21

be used if requested by the FS. 22

The cut stump method would be used on woody species that normally re-sprout after being cut. Herbicide 23

would be applied (spray or squirt) on the exposed cambium (living inner bark) of the stump immediately 24

after the trunk is cut. The outer bark and heartwood would not need to be treated since these tissues are 25

not alive, although they support and protect the tree’s living tissues. 26

Combustible free space treatment would be used around distribution and transmission poles with 27

equipment and hardware types that have a history of becoming an ignition source and around wood poles 28

in areas of high fire risk. Combustible free space treatment requires a minimum of a 10-foot radius around 29

poles be maintained as bare ground. The treatment utilizes herbicides designed specifically for bare 30

ground applications and can include nonselective, soil-active herbicides and pre-emergent herbicides. Soil 31

active herbicides would be applied year round. Pre-emergent herbicides require rainfall for incorporation 32

into the soil, would only be effective when applied prior to seed germination. 33



2.2.2.3 Proposed Herbicide Active Ingredients and Mix 1

The Proposed Action Alternative includes all herbicides for which the FS has completed a HERA. This is 2

not an exclusive list and additional products may be used as they are approved and registered for use by 3

the FS and EPA. 4

FS HERAs, incorporated by reference in this EA, address the potential risks to humans and non-target 5

plants and animals from using active ingredients in the proposed commercial herbicide formulations. 6

Various manufacturers offer multiple products approved for use that include these active ingredients, and 7

the risk assessments developed by the FS apply to these commercial formulations. 8

The application process would use a combination of products and adjuvants such as THINVERT, which 9

aid or modify the action of the product. The application process would use a combination of product and 10

paraffinic oil blend or water-based carrier. The herbicide formulation would vary as determined by 11

licensed applicators. Specific herbicide formulations would be developed for each Utility by their licensed 12

applicators and contractors to accommodate the site conditions of the particular area, buffer area 13

considerations, if any, and in keeping with regulations and manufacturer’s recommendations. Typical 14

mixtures would be approximately 95 percent adjuvants and inert ingredients, and 5 percent active 15

ingredient. A typical 100-gallon mixture, applied at the estimated rate of 10 gallons per acre, would 16

include approximately one-half gallon of combined herbicide products to one acre of land. Application 17

rates would not exceed those stated on manufacturers’ labeling. 18

2.2.2.4 Herbicide Treatment Procedures 19

This section identifies procedures that would be followed by the Utilities to ensure that risks to human 20

health and the environment from herbicide treatment actions would be kept to a minimum. 21

Posting Treated Areas 22

Posting of treated areas would be conducted in accordance with FS requirements and as listed on the 23

herbicide label. Treatment areas would remain off limits to the public until the manufacturer’s re-entry 24

period is met. 25

When posting areas that are accessible to the public (i.e., trails), notices would be placed at the points of 26

entry or along the perimeter of treated sites. The posting should include a notice that the area will be 27

treated, the name of the herbicide used, the date of the treatment, appropriate precautions to be taken, the 28

date of reentry (as per manufacture’s re-entry guideline), and a phone number for additional information. 29

The notices would be removed after the date of reentry. 30

Closed Chain of Custody 31

The Utilities would employ industry Best Management Practices using Closed Chain of Custody methods 32

(Goodfellow 2010). All mixing and filling of storage containers would occur at an off-site blending 33

facility and would utilize returnable/reusable supply containers. The herbicide mix would be contained in 34

sealed pre-mixed “ready to use” formulations. There would be no on-site mixing of herbicides. Support 35

vehicles would be available at intervals along the right-of-way corridor to transfer product from the 36

storage container to the application container. Transfer of product from the storage container to the 37

application container would utilize a closed, leak-proof connection or valve. The application process 38



would be supervised by a licensed applicator. Monitoring would be conducted to ensure that proper 1

application techniques, clean-up, personal protective equipment, and safety procedures are followed. Pre-2

mixed herbicide containers are equipped with a bar code for tracking and are returned to the supplier 3

when empty. There would be no waste disposal of chemical containers. 4

Best Management Practices 5

The application of herbicides is tightly controlled by State and Federal agencies. The FS is required to 6

follow all State and Federal laws and regulations applicable to the application of herbicides. The 7

following mitigation measures will be followed if herbicides are used: 8

All herbicide label requirements would be followed. 9

All applications would be under the direction of a Certified Pesticide Applicator. 10

Herbicides would be applied only by ground-based equipment. 11

All Best Management Practices would be followed 12

Applicators would be required to wear appropriate personal protective equipment as required on 13

the label. 14

All requirements in a Safety and Spill Plan (Appendix B) would be followed. 15

Use herbicides only when they will provide the most effective control relative to the cost and 16

potential hazard of other management techniques. 17

Choose the most effective herbicide that requires the least number of applications. 18

Choose the lowest effective rate of application. 19

Scout the area and identify sensitive situations like residential structures, campgrounds that will 20

be used by the public, etc. 21

Ensure meteorological conditions are favorable. 22

2.3 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY 23

To be determined through alternative development with FS. 24

2.4 CONSISTENCY WITH THE RESOURCE MANAGEMENT PLANS 25


2.5 SUMMARY COMPARISON OF ALTERNATIVES 27


29

Preliminary EA for Utility Right-of-Way i December 2014

Herbicide Treatment Project on FS National Forests Definitions and Abbreviations

Definitions

An abbreviated list of definitions is included in the document at this point to facilitate ease in reading

through the remainder of the document.

Active Ingredient: The chemical component that kills or controls the target vegetation.

Adjuvants: An adjuvant is any material added to an herbicide mixture that facilitates mixing, application,

or herbicide efficacy. An adjuvant enables an applicator to customize a formulation to be most effective

in a particular situation. Adjuvants include surfactants, stickers, extenders, activators, compatibility

agents, buffers and acidifiers, deposition aids, de-foaming agents, thickeners, and dyes.

Arc: The flow of electricity across a gap (through the air) from one conductor to another or to a grounded

object. Arcing potential is evaluated by using accepted industry standards such as the National Electric

Safety Code.

Capacitor Bank: An array of capacitors connected into a circuit. Capacitors are used to control voltages

supplied to the customer by eliminating the voltage drop in the system caused by inductive reactive loads.

Distribution Power Line: Circuits of the electrical supply system that distribute electricity at medium

voltage from a substation to transformers that service customers at the voltage required for customer use.

The circuits are less than 69,000 volts (69 kV) and serve to deliver electricity throughout a region to the

end-users.

Easement: A type of special use authorization (usually granted for linear right-of-way) that is utilized in

those situations where a conveyance of a limited and transferable interest in Forest Service System Lands

is necessary or desirable to serve or facilitate authorized long-term uses, and that may be compensable

according to its terms (36 CFR 251.51).

Hazardous Fuels: Living, dead, and decaying vegetation that forms a special threat of ignition and

resistance to control.

Herbicide: A chemical pesticide used to treat vegetation.

Industry standards, regulations, and recommendations governing maintenance: ANSI A300 Standards for

Tree Care Operations: Tree Shrub, and other Woody Plant Maintenance (ANSI A300 Part 1 – 2008; ANSI

A300 Part 7 – 2006), ANSI Z133.1 Standard for Tree Care Operations: Pruning, Trimming, Repairing,

Maintaining, and Removing Trees and Cutting Brush – Safety Requirements (ANSI Z133.1 2012), OSHA

1910.269 Regulations for Electric Power Generation, Transmission, and Distribution (29 CFR1910.269),

ISA Best Management Practices Utility Pruning of Trees (ISA 2004), National Electrical Safety Code

(NESC 2007), and Federal Energy Regulatory Commission (FERC) Mandatory Reliability Standards.

Native Species: Historically occurred or currently occur in a particular ecosystem and were not

introduced.

Preliminary EA for Utility Right-of-Way ii December 2014


Permit: A special use authorization which provides permission, without conveying an interest in land, to

occupy and use Forest Service System Lands or facilities for specified purposes, and which is both

revocable and terminable (36 CFR 251.51).

Rights-of-Way: Land authorized to be used or occupied for the construction, operation, maintenance, and

termination of a project or facility passing over, upon, under or through such land (36 CFR 251.51). For

this EA this will be interpreted to mean a corridor of land on which electric lines may be located. On FS

System Lands, rights-of-way are established through a permit process called a Special Use Permit or

Easement that allows the utilities to construct, operate, and maintain the power line. The table below lists

some typical rights-of-way. Permitted rights-of-way may vary within each voltage category.

Range of Permitted Right-of-Way by Line Voltage

Line Voltage Possible Rights-of-Way

(feet)*

Distribution (7.5 to 33kV) 15 to 60

69 kV 30 to 80

115 kV 55 to 100

230 kV 100 to 175

345 kV 150 to 200

500 kV 160 to 275

* The rights-of-way in this table are only a demonstration of what

may be a typical permitted right-of-way by line voltage.

Permitted rights-of-way vary within each voltage category, the

type of structure, and whether there are parallel lines present or

not.

Special Use Authorization: A permit, term permit, lease, or easement which allows occupancy, use,

rights, or privileges on Forest Service System Lands (36 CFR 251.5).

Switches: Distribution systems have switches installed at strategic locations to redirect power flows for

load balancing or sectionalizing.

Transformer: Converts the generator’s low-voltage electricity to higher voltage levels for transmission to

the load center, such as a city or factory.

Transmission Power Line: Heavy wires that carry large amounts of electricity at very high voltages over

long distances from a generating station to a substation. Transmission voltages range from 69,000 to

500,000 volts (69 – 500kV).

Undesirable Plants: Plant species that are harmful or injurious to the safe operation of electrical utility

lines that can include native species indigenous to the planning area, but not including species listed as

endangered by the Endangered Species Act.

Utility Vegetation Management: The process of managing vegetation surrounding utility lines for the

purpose of providing safe, efficient and reliable delivery of electricity while minimizing vegetation

related fires. Vegetation management includes routine vegetation maintenance, vegetation control around

poles, structures, and other electric facilities. Proper clearance must be maintained at all times between

Preliminary EA for Utility Right-of-Way iii December 2014


power lines, trees, the ground, and buildings. Vegetation management involves the treatment of

vegetation, pre- and post-inspections of vegetation, and disposal of vegetation.

Wildfires: Unplanned, unwanted wildland fires.

Preliminary EA for Utility Right-of-Way iv December 2014


List of Abbreviations

ANSI American National Standards Institute

APS Arizona Public Service

BLM Bureau of Land Management

cc cubic centimeter

EA Environmental Assessment

EPA United States Environmental Protection Agency

FERC Federal Energy Regulatory Commission

FS Forest Service

HERA Human Health and Ecological Risk Assessment

ISA International Society of Arboriculture

IVM Integrated Vegetation Management

kV kilovolt

NESC National Electrical Safety Code

OSHA Occupational Safety and Health Administration

PEIS Programmatic Environmental Impact Statement

SRP Salt River Project Agricultural Improvement and Power District

USC United States Code

USDA United States Department of Agriculture

USDI United States Department of Interior

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