Kingdom Community Wind Transmission Component Project File ...

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Transportation Land Development Environmental S e r v i c e s

7056 US Route 7 Post Office Box 120 North Ferrisburgh, VT 05473 Telephone 802.425.7788 Fax 802.425.7799 www.vhb.com

Memorandum

To:

Kingdom Community Wind Transmission Component Project File

Date:

Project No.:

From:

Adam R. Crary, PWS, PWD

Re:

Revised: June 9, 2011 57346.02 West Farman Hill/Route 100 Serpentine Outcrop Natural Community Management Plan

Green Mountain Power, Inc. (GMP) and Vermont Electric Cooperative Inc. (VEC), as part of GMP’s planned Kingdom Community Wind (KCW) project in Lowell, Vermont, plan to upgrade, through pole and line replacement, the existing VEC overhead utility line from the project site in Lowell up to the existing Vermont Transco, LLC (VELCO) 46kV line in Jay, Vermont. From there, the VELCO line will also be reconductored to the proposed Jay Tap. The planned replacement involves the replacement of existing wooden utility structures, realignment where necessary, and vegetation clearing to meet current line reliability standards. In one location near the Lowell/Westfield town line, the planned alignment bisects a Serpentine Rock Outcrop natural community which is considered very rare in Vermont, and is also habitat for the Vermont-threatened Green Mountain Maidenhair fern (Adiantum viridimontanum) (“GMMF”), as well as other rare vegetation. The following sections will outline the Objective of this management plan (the Plan), describe the protected resource and threats, and outline specific management measures. OBJECTIVE The purpose of this memorandum is to outline a plan to ensure the protection and sustained viability of the Serpentine Rock Outcrop habitat and associated rare vegetation during replacement (construction) and subsequent periodic maintenance (post-construction) associated with the planned project within the legal ROW limits. The Plan has been prepared to address concerns raised by the Vermont Natural Heritage Information Project (NHIP) during the Vermont Section 248 review process that construction and subsequent periodic maintenance could result in adverse effects to the outcrop community and associated protected or rare vegetation. This Plan is intended to specifically address management requirements for the singular natural community known as the “West Farman Hill/Route 100 Serpentine Outcrop”,

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Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 2 Revised: June 9, 2011

and should also be a supplement to the comprehensive Vegetation Management Plan for Vermont Electric Cooperative, Inc.1 or current plan for vegetation maintenance used by VEC for this section of the transmission line. Currently, the VEC Vegetation Management Plan uses an Integrated Vegetation Management (IVM) technique which incorporates a combination of methods, both physical and chemical, for managing undesirable vegetation within VEC ROWs. The techniques used for managing vegetation in different ROW segments, which are developed as part of the five-year management cycle, are determined based on regular surveys to monitor conditions within the ROW. This Plan does not include any provisions or recognize any management objectives that are inplace as part of maintenance or operation of Vermont Route 100, which is immediately adjacent to the natural area habitat, as the ongoing use and maintenance of the roadway is beyond the control of both GMP and VEC. This Plan also cannot account for the landowner activities within or beyond the legal ROW limits. WEST FARMAN HILL/ROUTE 100 SERPENTINE OUTCROP DESCRIPTION Serpentine outcrops are very limited in distribution in Vermont and occur where the ultramafic serpentenite bedrock is exposed at the surface. According to Thompson and Sorenson (2005)2, due to harsh chemical environments caused by naturally occurring nutrient deficiencies and minerals that are toxic to some plants, serpentine outcrops are typically sparsely vegetated and often contain unique vegetation adapted for growth in such conditions. As depicted on the West Farman Hill/Route 100 Serpentine Outcrop Management Plan Exhibit (Attached), this rare outcrop habitat comprises approximately 0.70-acre of the area investigated for the planned alignment, and is found in one location off the eastern flank of Route 100, just south of the Lowell/Westfield town line. Outcrop Habitat Location Description: 1.

Northern terminus: Approximately 150-feet north from existing VEC Structure JYT43 (44°

49’ 59.9” N Latitude, 72° 25’ 55.2” W Longitude)

Packer, S.L. 2009. Vegetation Management Plan for Vermont Electric Cooperative, Inc., Transmission & Distribution Systems, March 2009 Revision. 1

2

Thompson, E.H, E.S. Sorenson. 2005. Wetland, Woodland, Wildland: A guide to the natural communities of Vermont. Vermont Department of Fish and Wildlife and the Nature Conservancy.

Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 3 Revised: June 9, 2011

2.

Southern terminus: Approximately 75-feet south from existing VEC Structure JYT42 (44°

49’ 59.9” N Latitude, 72° 25’ 55.2” W Longitude). In this location, the refurbished alignment coincides with the existing VEC ROW that currently bisects the natural community. The outcrop habitat is likely naturally open due to the exposed ultramafic rock outcropping, but enhanced by the existing VT Route 100 and overhead utility maintenance clearing.

As described below, this community location supports the state-

threatened GMMF, as well as the unlisted but rare large-leaved sandwort (Moehringia macrophylla) (LLS). This location is considered a state-significant natural community. As shown on the West Farman Hill/Route 100 Serpentine Outcrop Management Plan Exhibit (Attached), the outcrop supports the Vermont threatened GMMF. This map depicts the GPSlocated3 mapping of individual stems or where stem densities were too high to map plant individuals, the boundaries of distinct clusters. Based on estimates conducted in the field in 2010, there were approximately 900 stems

present

(see

the

included

photograph of GMMF within the outcrop habitat below). area

surveyed,

the

Within the

GMMF grows

where the outcropping or clastic rubble is present at or near the surface and does not appear to be restricted by the associated vegetative habitat condition. Individual stems were located within the drainage ditch along Route 100 and continuing

through

the

exposed

outcrop and into the adjacent white pine (Pinus strobus) forest. Individual stems were noted growing near the base of the VEC utility pole #JYT142 as well as adjacent to the neighboring cow pasture. One point of interest is that the largest cluster of GMMF occurs within a dense stand of regenerating white pine. Within this serpentine outcrop habitat, the rare LLS was also noted in high abundance, but was not mapped as impacts to this species are not reviewed under state or federal protective mechanisms.

Location data collected using Trimble ProXH GPS receivers capable of real-time sub-meter accuracy and post-processed using Pathfinder Office software. 3

Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 4 Revised: June 9, 2011

THREATS The serpentine outcrop habitat and associated rare plants occur on naturally exposed bedrock outcrops and rubble and have thrived, in spite of past, regular disturbances associated with ROW maintenance of the existing VEC utility line, and location adjacent to Route 100. As the planned replacement activities will not result in a net change in land use or disturbance type from existing conditions, threats to the habitat or the rare plant elements, particularly the GMMF, are not changed from those that currently exist. However, potential threats to habitat condition and/or individual GMMF stems, do occur from construction.

Additionally, the

previous maintenance regime for the existing VEC ROW has occurred on cycles less frequent than the current maintenance cycle (5 years). The following describes potential threats to the habitat and/or GMMF as a result of the planned replacement activity and post-construction maintenance of the overhead transmission line: •



Construction Threats: 

Construction traffic



Construction equipment



Clearing disturbance



Existing structure removal



New structure placement

Post-Construction Threats: 

Maintenance clearing (using improper methods)



Invasive vegetation

CONSTRUCTION MANAGEMENT PLAN (AVOIDANCE/MINIMIZATION) To avoid or minimize direct impacts to GMMF, LLS, and overall condition of the natural community, the following steps will be implemented during construction planning and replacement activity: •

Pre-Construction:

1.

Replacement design to minimize the number of new structures to be placed within the

serpentine outcrop habitat. 2.

Replacement design will site new pole structures in locations to avoid the mapped GMMF

locations/clusters, while also maintaining required setbacks from Route 100.

The attached

exhibit depicts the locations of the current designed new pole structures (as well as existing

Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 5 Revised: June 9, 2011

structure), which have been sited to avoid GMMF, the final locations remaining subject to infield adjustment per item 8, below. 3.

The limits of the serpentine outcrop natural area will be depicted on project plans.

4.

Though not protected under state and federal protective mechanisms, LLS are an indicator

of the serpentine outcrop community and will be GPS located and mapped during the 2011 growing season. 5.

The limits of the serpentine outcrop natural community will be demarcated with

flagging/barrier tape. 6.

GMMF and LLS plants in close proximity to the limits of disturbance from pole removal or

placement will be protected by barrier fencing or flagging. 7.

Access routes from Route 100 to new structure locations will be demarcated with

flagging/barrier tape. 8.

Replacement pole locations will be reviewed and staked with the aid of a qualified botanist

during the growing season and prior to replacement activities to allow for in-field adjustment to avoid impacts to GMMF and other rare vegetation. 9.

If direct impacts to GMMF, based on the design plan and the GPS-mapped individuals or

clusters are unavoidable, a Threatened and Endangered Species Takings Permit will be applied for and obtained from the ANR-NHIP prior to any construction work that will result in a GMMF taking. At this time, planned project activities will be accomplished with no direct impacts to GMMF and no takings permit would then be required. 10. If greater than 25% of the LLS population is to be impacted, the plants shall be transplanted and/or seeds collected for propagation adjacent to disturbance area. •

Construction:

1.

If construction occurs within the growing season (from May 3 to October 6 on average4), a

qualified botanist will be present at the outset of construction activity within the natural area. The botanist will be responsible for reviewing the locations of the existing structures to be removed, the new structures, and design access for GMMF as well as other rare species. The botanist will make recommendations, as necessary, to the contractor to avoid/minimize impacts, as well as providing any appropriate on-site mitigation measures. The botanist will train both the on-site contractor as well as the onsite compliance inspector to properly identify the rare vegetation species present.

4

Grow ing season d eterm ined based on the 50% p robability that air tem p eratu res w ill be 28 d egrees F or higher as p resented by the N RCS WETS Station VT5542 for Orleans Cou nty, Verm ont.

Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 6 Revised: June 9, 2011

2.

If construction occurs during the time when GMMF is observable in vegetative form and

new individuals are found, and if during construction, impacts to GMMF are determined to be unavoidable, construction will have to cease until an endangered species permit is obtained. 3.

Trained compliance inspectors will be present to provide oversight for work performed

within this natural area. 4.

Heavy equipment will be prohibited within the natural area and limited to work from the

Route 100 road ROW. 5.

Existing wooden pole structures will be removed without impacting the existing

vegetation. Poles will be flush cut and abandoned in place. 6.

Any brush or tree clearing will be completed by hand with trees felled away from high

densities of GMMF if occurring within the growing season. 7.

No wood chips will be broadcast within the natural area.

8.

Soil disturbance will be limited to auguring for new pole placement or necessary pole

stabilization within a demarcated disturbance area, and if needed, surrounded by silt fence as determined the On-Site Plan Coordinator. 9.

Any excavated soil will be removed from site.

10. All construction equipment used within the natural areas will be kept clean of any vegetation material transported from other sites. 11. All barricade flagging/tape used to protect the natural areas during construction will be removed following construction activity (to protect the anonymity of the natural area in the highly visible location). POST-CONSTRUCTION MANAGEMENT PLAN (MAINTENANCE) To avoid or minimize direct impacts to GMMF, LLS, and overall condition of the natural community, the following steps will be implemented within the ROW limits following construction as part of transmission line integrity and reliability maintenance: 1.

Regular

maintenance/inspection

access

to utility

structures will

follow

current

practices/procedures implemented by VEC for the existing utility line unless indicated herein. 2.

A qualified botanist will inspect annually for a duration of three (3) growing seasons to

determine GMMF and LLS distributions at/near disturbance locations and make observations for considerations related to future management efforts.

Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 7 Revised: June 9, 2011

3.

Understory and overstory vegetation maintenance will be implemented in accordance with

the Vegetation Management Plan ascribed to by VEC and associated electrical reliability standards, unless indicated herein. 4.

Understory and overstory vegetation maintenance or danger tree clearing will be

completed in accordance with VEC’s regular maintenance cycle and treatment method provided that such treatment methods do not result in unintended herbaceous vegetation mortality. Mechanical clearing methods (during dormant season) are recommended, particularly handclearing methods employing chainsaw and brushsaw cutting techniques. If Best Management Practices (BMPs) are developed in concert with the NHIP, such BMPs may be incorporated into VEC’s IVM procedures within the natural area 5.

No foliar herbicide will be applied. Any cut-stump application of herbicide will be greater

than 1 meter from any individual GMMF or LLS. 6.

Areas of soil disturbed during construction will be monitored by a qualified botanist for

five (5) growing seasons, following construction, for the presence of invasive or noxious vegetation as included on the Vermont Agency of Agriculture Quarantine Rule (2002)5 If any species are found to be present within the soil disturbance areas, they will be physically removed and properly disposed of. The results of the monitoring will be compiled in a brief report to the NHIP that will also include site photographs and a description of any remediation measures taken. 7.

If any seeding or planting is performed, it should be done in consultation with NHIP.

ATTACHMENT • West Farman Hill/Route 100 Serpentine Outcrop Management Plan Exhibit, dated Revised: June 8, 2011

Vermont Agency of Agriculture, Food and Markets, 2002. Quarantine #3- Noxious Weeds. Available online: http://www.vermontagriculture.com/ARMES/plantindustry/plantPathology/weeds/documents/Noxi ousWeedsQuarantine.pdf 5

ATTACHMENT 

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2010-TB-M R

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WESTFIELD

Site Location

[ ¨ Southern Edge of Serpentine Outcrop: 44° 49ʹ 54.6 ʺN  72° 25ʹ 58.1ʺ W

LOWELL

2009-SC-C11

Legend VHB Streams (2009)

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Existing Utility Poles

Ephemeral

# 0 Proposed Utility Poles

Intermittent

Investigation Area

Perennial

Road

VHBP Wetlands (2009) Class II Class III

20ʹ Contour

Kingdom Community Wind Lowell, Westfield and Jay Vermont Transmission Component West Farman Hill/Route 100  Serpentine Outcrop Management Plan Exhibit November 16, 2010 Revised: June 8, 2011

Serpentine Outcrop Community Boundary

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Sources: Ortho Layer Lowell South by Vermont Mapping Program (1999); VHD Streams (2008),  VSWI Wetlands from ANR (Interim 2010), roads layer provided by VCGI (2008); Wetlands and Streams by VHBP (2009‐2010), GMMF surveyed by VHBP (2010); LLS surveyed by VHB (2011); Pole locations from Krebs & Lansing (2011).

100ʹ Contour

Stream (VHD 2008) 50

Green Mountain Maidenhair Fern Green Mountain Maidenhair Fern (Clusters) Prepared by: TTK

25

0

Feet

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50 F:\57346.00\GIS\project\Transmission Line\NaturalResources\RTE_NNHP\Serpentine  Outcrop_RTE_WithoutLLS.mxd