Exh. Pet.-JAN-13
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
Vanasse Hangen Brustlin, Inc.
Memorandum
To:
Kingdom Community Wind Transmission Component Project File
Date:
Project No.:
From:
Adam R. Crary, PWS, PWD
Re:
November 18, 2010
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, re‐ alignment 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 November 18, 2010
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 in‐ place 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)
1 Packer, S.L. 2009. Vegetation Management Plan for Vermont Electric Cooperative, Inc., Transmission & Distribution Systems, March 2009 Revision.
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. 2
Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 3 November 18, 2010
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). 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 GPS‐ located 3 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). Within the area surveyed, 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 large‐leaved sandwort 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 November 18, 2010
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, large‐leaved sandwort, 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 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 current proposed new pole structures (as well as existing structure), subject to change with design progress.
Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 5 November 18, 2010
3.
The limits of the serpentine outcrop natural area will be depicted on project plans.
4.
The limits of the serpentine outcrop natural community will be demarcated with
flagging/barrier tape. 5.
Access routes from Route 100 to new structure locations will be demarcated with
flagging/barrier tape. 6.
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 minimize impacts to GMMF and other rare vegetation. 7.
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 from the NHIP. Mitigation for any takings would be included as part of the permit, and may result in transplanting affected individuals or donating whole plant or vegetative material to botanical research focused on GMMF conservation/species biology. At this time, planned project activities will be accomplished with no direct impacts to GMMF and no takings permit would then be required. •
Construction:
1.
If construction occurs within the growing season (from May 3 to October 6 on average 4 ), 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. 2.
If construction occurs during the time when GMMF is observable in vegetative form and
new individuals are found, and impacts to GMMF are unavoidable, the NHIP will be consulted for appropriate mitigation measures and an after‐the‐fact Takings Permit 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.
Growing season determined based on the 50% probability that air temperatures will be 28 degrees F or higher as presented by the NRCS WETS Station VT5542 for Orleans County, Vermont.
4
Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 6 November 18, 2010
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. 9.
Disturbed soil will be stabilized in accordance with the approved Erosion Prevention and
Sediment Control (EPSC) Plan. 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, large‐leaved sandwort, 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. 2.
Understory and overstory vegetation maintenance will be implemented in accordance with
the Vegetation Management Plan ascribed to by VEC and associated electrical reliability standards. 3.
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 are recommended, particularly hand‐clearing 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, including the appropriate use of chemical treatment when necessary. 4.
Areas of soil disturbed during construction will be monitored for one (1) growing season
following construction for the presence of invasive or noxious vegetation as included on the
Kingdom Community Wind Project – Transmission Component West Farman Hill/ Route 100 Serpentine Outcrop Natural Community Management Plan Project No.: 57346.02 Page: 7 November 18, 2010
Vermont Invasive Exotic Plant Fact Sheet (2003) 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. ATTACHMENT •
West Farman Hill/Route 100 Serpentine Outcrop Management Plan Exhibit
Vermont Agency of Natural Resources and The Nature Conservancy. 2003 (revised). Vermont Invasive Exotic Plant Fact Sheet Series. Available online: http://www.vtfishandwildlife.com/library/factsheets/nongame_and_Natural_Heritage/Invasive_Exotic_Plant_FactSheet.pdf
5
2009-C10
780
2010-TB-MR
Northern Edge of Serpentine Outcrop: 44° 49' 59.9" N 72° 25' 55.2 "W
Top of Bank Missisquoi River
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¨ [ Southern Edge of Serpentine Outcrop: 44° 49' 54.6 "N 72° 25' 58.1" W Legend
VHB Wetlands (2009) Class II Class III VHB Streams (2009)
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! . Existing Utility Poles # 0 Proposed Utility Poles
e "1 Investigation Area IN • • I
Road Ephemeral 20' Contour Intermittent 100' Contour Perennial Stream (VHD 2008) Serpentine Outcrop Community Boundary Green Mountain Maidenhair Fern Green Mountain Maidenhair Fern (Clusters)
Prepared by: CMM
Kingdom Community Wind Lowell, Westfield and Jay Vermont Transmission Component West Farman Hill/Route 100 Serpentine Outcrop Management Plan Exhibit November 16, 2010 50
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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), Plants surveyed by VHBP (2010); Pole locations from Krebs & Lansing (2010).
Vanasse Hangen Brustlin, Inc. 50 F:\57346.00\GIS\project\Transmission Line\NaturalResources\RTE_NNHP\Serpentine Outcrop_RTE_ManagementPlan.mxd