NATIONAL GRID 2024 YEARLY OPERATIONAL PLAN RECEIVED
DEC 12 2023 nationalgrid
December 5, 2023
CITY OF SALEM
BOARp OF HEALTH
Salem Mayor Dominick Pangallo
93 Washington Street
Salem, MA 01970
Dear Mayor Dominick Pangallo:
In compliance with 333 CMR 11.06,45 Day Yearly Operational Plan Public Notice, Review and Comment,
please review National Grid's 2024 Yearly Operational Plan (YOP) at the following website (hard copy available
upon request): https://www9.nationalgridus.com/transmission/c3-8 standocs.asl _A copy of the
Environmental Monitor Notice is enclosed and published under the Massachusetts Environmental Policy Act
(MEPA).
The map(s)for your municipality can also be found on the above website(scroll through the pdf to your
municipality). If you have any trouble viewing the maps, please contact me.
Please review the YOP map(s) that locate the right-of-way corridors and the plotted location of known
sensitive areas including public and private drinking water supplies. If there are any additional sensitive areas
located on or near the rights-of-way, please advise us as soon as possible so we may establish GIS permanent
records and implement appropriate field protective actions. We particularly rely on this process to collect
corrections to the public wells and to record the location of private wells.
National Grid's YOP details specific information pertaining to the intended 2024 program. Please note that the
YOP also lists the rights-of-way from the 2023 treatment program in case National Grid needs to request a
"touch-up" retreatment of scattered locations from our contractor(s). If upon review of the previous year's
treatments, National Grid finds a site(s) within your municipality that need follow-up treatments, this letter
serves as notification of that follow-up treatment.The individual landowner(s)will also be notified about this
work. Please note that scheduled rights-of-way are subject to change based on workplan constraints.
This notification also serves as a 21-day herbicide application notification. As detailed in National Grid's Five-
Year Vegetation Management Plan (VMP) and Yearly Operational Plan (YOP),this treatment is conducted as a
component of an integrated vegetation management(IVM) program that also utilizes mechanical and natural
control techniques. National Grid's Five-Year Vegetation Management Plan (2024-2028) is posted at the
following website (hard copy available upon request) htt ,/: www9.nationalgridus.com%transmissionic3-
8 standocs.asp .
As described in the VMP and YOP,the program will consist of a late winter-spring mechanical control, cut
surface (CST), basal treatment, or dormant stem; a summer selective foliage or cut stubble, and, as necessary,
fall CST, basal,or dormant stem treatments.
In compliance with 333 CMR 11.06-11.07, no herbicide applications will occur before the conclusion of the 45-
day YOP review period,the 21 day treatment notice and the 48 hour newspaper notice. At the end of these
review periods,which can run concurrently, no application shall commence more than ten days before nor
conclude more than ten days after the treatment periods listed above.
Municipality: Salem ROW: 6050
Potential Treatment Periods*
February 1,2024—May 30,2024 May 30,2024-Oct 15,2024 1 Oct 15,2024—Dec 31,2024
CST Foliar CST
Basal CST Basal
_Dormant stem Basal Dormant Stem
Cut stubble
*The exact treatment dates are dependent upon weather conditions and field crew progress.
Commonwealth of Massachusetts recommended herbicides for use in sensitive areas listed in Section 7 (pages
13-15)of the YOP will be selectively applied to target vegetation by experienced, Massachusetts'
licensed/certified applicators that walk along the rights-of-way using backpack equipment. Copies of the
manufacturers' herbicide labels and fact sheets are also included in the YOP,Appendices 8 and 9.
The work will be performed by one of the following vegetation management vendors:
Lewis Tree Service,Inc. Stanley Tree Vegetation Control Service,Inc. Davey Tree Expert Co.
300 Lucius Gordon Drive 662 Great Road 2342 Main Street 1500 N Mantua St
West Henrietta, NY 14586 North Smithfield,RI 02896 Athol, MA 01331 Kent,OH 44240
(585)436-3208 (401)765-4677 (978)249-5348 800-445-8733
Lucas Tree Experts BluRoc North EasternTree Service Rainbow Treecare
12 Northbrook Drive 15 Atwood Dr,Suite 301 1000 Pontiac Ave 11571 K-Tel Dr.
Falmouth, ME04105 Northampton, MA01060 Cranston, RI 02920 Minnetonka, MN 55343
(800)339-8873 (413)887-3653 (401) 941-7204 952-922-3810
This informational 21-day notification follows Chapter 132B, section 6B of the Massachusetts General Laws,
333 CMR 11.05-11.07 Rights of Way Management and Chapter 85,Section 10 of the Acts of 2000. National
Grid's vegetation management program is subject to federal and state regulations only. By statute, local
permits or rulings are not applicable.
For inquiries concerning safety of the herbicides, please contact:
MDAR-Pesticide Division-ROW Coordinator
251 Causeway Street,Suite 500
Boston, MA 02114-2151
Telephone:(617) 626-1782
Please contact me if you have any questions about the application and monitoring of the vegetation
management program. Email: mariclaire.rigby@nationalgrid.com Phone: 781-290-8310
Sincerely,
s
Mariclaire Rigby
Principal Vegetation Strategy Specialist
CC: Board of Health, Conservation Commission, Private and Public Water Suppliers
Massachusetts Department of Agricultural Resources
Municipality: Salem ROW: 6050
THE COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS
Department of Agricultural Resources
DAR
iJlv�
225 Turnpike Road, 3,d Floor, Southborough,MA 01772
617-626-1700 fax: 617-626-1850 www.mass.gov/agr MASSACHUSETTSDEPARTMEHT
OF AGRICULTURAL RESOURCES
Maura T.Healey Kimberley Driscoll Rebecca L.Tepper Ashley E.Randle
GOVERNOR LIEUTENANT SECRETARY COMMISSIONER
GOVERNOR
NOTICE
Pursuant to the provisions of the Rights-of-Way Management Regulations,333 CMR 11.00,to apply herbicides to control
vegetation along rights-of-way, a five year Vegetation Management Plan(VMP)and a Yearly Operational Plan(YOP)must be
approved by the Massachusetts Department of Agricultural Resources(MDAR). National Grid has submitted and holds a
current VMP,therefore,notice of receipt of a YOP and procedures for public review is hereby given as required by Section
11.06(3).
National Grid has submitted a YOP to MDAR for 2024 and National Grid's YOP identifies the following
municipalities as locations where they intend to use herbicides to treat their electric Rights-of-Way in 2024:
Abington Chelmsford Hanover Melrose Raynham Stoughton
Adams Clarksburg Haverhill Mendon Reading Sturbridge
Andover Colrain Heath Methuen Rehoboth Swampscott
Attleboro Dighton Holbrook Milford Rowe Swansea
Auburn Dracut Hopedale Millbury Salem Taunton
Avon East Lawrence Monroe Saugus Tewksbury
Bridgewater
Ayer Easton Leicester Montague I Seekonk Uxbridge
Berkley Florida Leominster North Adams Shelburne West
Bridgewater
Billerica Gill Littleton North Somerset Westford
Andover
North
Bridgewater Grafton Lowell Reading Spencer Whitman
Brockton Greenfield Lynnfield Pembroke Sterling
In 2024 National Grid will conduct a selective herbicide treatment program on their rights-of-way as part of an Integrated
Vegetation Management(IVM)program on transmission and distribution lines.
The intended vegetation control program will be consistent with the guidelines set forth in National Grid's VMP and YOP.
Herbicides will be selectively applied to target vegetation by licensed/certified applicators carrying backpack or hand held
application equipment.
National Grid will only use herbicides recommended by MDAR for use in sensitive areas for their IVM program. Pursuant to
333 CMR 11.04,no herbicides will be sprayed within any designated"no spray sensitive sites." Instead,mechanical only
methods will be used to control vegetation in these areas.
Public notification will be provided to each"affected"municipality at least twenty-one days prior to any herbicide application
and in a newspaper notification at least 48 hours before the beginning of the spray season.
In accordance with 333 CMR 11.06(2),National Grid's YOP includes the identification of target vegetation;methods of
identifying,marking and protecting sensitive areas;application techniques;the herbicides,application rates,carriers and
adjuvants proposed for use;alternative control measures,a list of the application companies and YOP supervisor;procedures
for handling,mixing and loading herbicides;emergency resources including local,state and federal emergency telephone
numbers;maps of the rights-of-way that include mapped sensitive areas,and herbicide fact sheets and labels.
PUBLIC REVIEW
MDAR seeks to verify the location of sensitive areas defined in Section 11.02 and reported in the YOP. MDAR itself has a
limited ability to survey the geography,land use and water supplies in all the communities through which rights-of-way pass.
Municipalities have most of this information readily available,and the particular knowledge with which to better certify the
sensitive areas in their communities. MDAR,therefore,requests,and urges the assistance of the"affected"municipalities in
reviewing the completeness and accuracy of the maps contained in the submitted YOP.
The YOP can be viewed on MDAR's website: htti)://www.mass.Lov/eea/at encies/agr/pesticides/vegetation-management-and-
yearly-operation-plans.html or National Grid's website: https://www9.nationalgridus.com/transmission/c3-
8 standocs.asp
MDAR has established the following procedures for this review:
Copies of the YOP and this Notice will be sent by the applicant to the Conservation Commission,Board of Health(or
designated health agent),the Head of Government(Mayor,City Manager,Chair of the Board of Selectman)and appropriate
water suppliers of each municipality where herbicides are to be applied during the calendar year of 2024;and if applicable,to
the Natural Heritage Endangered Species Program of the Massachusetts Department of Fisheries and Wildlife,the
Massachusetts Water Resource Authority and the Massachusetts Department of Conservation and Recreation. Municipal
agencies and officials will have forty-five days,following receipt of the YOP,to review its map for inaccuracies and omissions
in the location of"sensitive areas not readily identifiable in the field."
Municipal agencies and officials are requested to forward the YOP to the appropriate official(s)in their municipality who are
qualified to certify the accuracy of the sensitive areas indicated on the maps. The maps should then be"corrected" and
returned to the applicant and a copy should be sent to MDAR,at the address listed below,within the forty-five day review
period. If a city or town needs more time to carry out this review,it should send a written request for an extension to MDAR
and cite why there is a"good cause" for requesting additional time.
The applicant is required to make corrections and the corrected maps will be sent back to the city/town that requested the
disputed changes within fifteen days of receipt of the request. MDAR will decide whether or not the YOP should be approved
without the requested changes. MDAR will consider the"final approval" of a YOP individually for each municipality.
The twenty-one day public review period of the Municipal Notification Letter may serve concurrently with the forty-five day
YOP review period in order to provide public notifications as required by 333 CMR 11.06-7,if the applicant has an approved
VMP and if all the requisite city-town offices that received copies of the YOP completed their review and all corrections were
duly made by the applicant and approved by MDAR.
A failure by the city/town to respond to the applicant's submission of the YOP within the forty-five day period will
automatically be considered by MDAR to indicate agreement by the municipal officials with the sensitive area demarcations
provided by the applicant in their YOP.
Any questions or comments on the information provided in this Notice and the procedures established for the municipal review
outlined above should be addressed to:
Clayton Edwards,Rights-of-Way Programs
Massachusetts State Pesticide Bureau
225 Turnpike Road,
Southborough,MA 01772
Any questions or comments regarding the YOP should be addressed to:
Mariclaire Rigby
Lead Vegetation Strategy Specialist
National Grid Vegetation Management Strategy
939 Southbridge Street,Worcester,MA 01610
COMMENT PEROID ENDS AT THE CLOSE OF BUSINESS (5prn)Friday,January 22,2024
nafionalgr*ld
RIGHT-OF-WAY VEGETATION MANAGEMENT
Additional Information about National Grid's Integrated Vegetation Management(IVM)Program:
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National Grid utilizes a program called Integrated Vegetation Management(IVM) to maintain its rights-
of-way(ROW)floor(WIRE ZONE AND BORDER ZONE in the above illustration).The ROW is the off-road
section of our lines,these are not the poles and lines that run along the roadside.The IVM program
encourages the establishment of a low growing plant community within the ROW using mechanical,
biological, & herbicide treatments. Our IVM program is based on 4-5-year cycles which schedule crews
to target incompatible vegetation as selectively as possible and then allows early successional ecological
communities (low-growing plants and shrubs)to help maintain compatible vegetation between
treatment programs. Because we have been using this program since the 1960's our ROWS consist
mainly of compatible growing species. It's important to note that the cycles allow us to treat different
ROWs in our system each year, so not all the ROWS in one town will necessarily be treated in the same
year.
The vegetation management work is being performed in accordance with 333 CMR 11.00 Rights of Way
Management and the provisions of the Massachusetts Wetlands Protection Regulations (310 CMR
10.02(2)(a)(2)that allow for the maintaining, repairing, or replacing, but not substantially changing or
enlarging, existing structures or facilities.This work is done to keep vegetation away from electrical
transmission lines and facilities to prevent power outages and ensures the safety and reliability of the
existing lines therefore, it constitutes maintenance of utility structures and facilities.
The herbicide maintenance work is also covered under 310 CMR 10.03 (6): Presumption Concerning
Application of Herbicides. (a)Any application of herbicides within any Area Subject to Protection under
M.G.L. c. 131, §40 or the Buffer Zone associated with a structure or facility which is: 1. existing and
lawfully located; 2. used in the service of the public; and 3. used to provide electric, gas,water,sewer,
telephone,telegraph and other telecommunication services shall be presumed to constitute work
performed in the course of maintaining such structure or facility, and shall be accorded the exemption
of such work under M.G.L.c. 131, §40,only if the application of herbicides to that structure or facility is
performed in accordance with such plans as are required by the Department of Food and Agriculture
pursuant to 333 CMR 11.00: Rights of Way Management, effective July 10, 1987.
National Grid uses field GIS software to gather data on the ROW. Before we begin any ROW vegetation
maintenance work, professionally trained forestry staff field inventory the ROW 1-2 years ahead of the
scheduled maintenance year and prescribe the work for the crews. Each site is GIS mapped and
designated with a land use type, site prescription, and any special notes. When making the prescription
all land use factors are considered: proximity to water, sensitive areas,wetlands, landowner concerns,
priority habitat, etc.GIS shapefiles/locations of wetlands and other sensitive areas provided from the
state and local municipalities are added to our GIS. In addition, all the necessary state listed buffers have
also been applied to our GIS. (Please see Appendix 6 of the YOP for the list of buffers). National Grid
Forestry staff and contracted field crews conducting the ROW work all use the GIS software in the field
to help identify the work and sensitive area requirements.
In addition to using GIS field software, National Grid chooses to only use herbicides from the MA
Sensitive Materials List.These are herbicides that may be used in sensitive areas. (ex:wetlands). In areas
where we use herbicides,the herbicide treatments are selectively applied by trained, licensed
applicators using hand-held equipment.Two methods of application are primarily used.A preparatory
Cut and Stump Treatment (CST) is made where trees must be hand cut near inhabited areas, roads, and
for all trees over 12 feet tall. A foliage application consisting of the same materials is made selectively to
target species only less than 12 feet tall over the remaining portion of the right-of-way. In both
treatment methods, applicators walk to each target plant and apply minimal amounts of herbicide.
National Grid does not utilize any broadcast treatments. All herbicides have been approved for use by
the U.S. Environmental Protection Agency as well as the MA Department of Agriculture (MDAR).
Herbicide use in Massachusetts is solely regulated by MDAR. https://www.mass.gov/rights-of-way-
i-managemen. .Important:if you note any additional sensitive areas,please notify us so we
can add them to our GIS and apply the necessary buffers.
National Grid is currently taking part in a study to quantify the biodiversity found within our rights-of-
way. https://www.tdworld.com/vegetation-man,.`-.,,-IIL, .-;573 nati al-Frids-biodiversity-
study-for-integrated-vegetation-management
For more information about the study: https://bioaudit.acrt.com/national-grid/