The use of herbicides on ROW crossing USFS land or BLM land is a fairly complex issue. On the one hand are the federal agencies and their respective goals for managing the ecosystem, on the other is the utility with the desire to maintain vegetation in the ROW to provide safe reliable service to their customers.

I, along with many others in the UVM industry contend that these two goals are not mutually exclusive of each other. In fact, there has been a tremendous amount of research to suggest that proper use of IVM (integrated vegetation management) enhances the right of way plant and animal communities. The most extensive research in this regards is the State Game Lands 33 Research and Demonstration Project that was initiated in 1952 by Drs. Bramble and Byrnes and continues today under the direction of Dr. Richard Yahner. The research proves that IVM activaties actually improves biodiversity of plant and animal communities living along and in the ROW.

In research published in 1994 the USFS acknowledges the benefits and value of herbicide use on federal land.


http://www.srs.fs.usda.gov/pubs/ja/ja_mcmahon003.pdf

In this article published from the proceedings of the Southern Weed Science Society, the authors conclude that “Six roles for herbicide treatments in EM (ecosystem management) are suggested: create an maintain desired habitats; create mixed an uneven aged stands; restore damaged landscapes; control exotic, noxious and poisonous plants, maintain recreational areas, trails and scenic vistas an manage rights-of-way for multiple use.

At issue have been the National Environmental Policy Act (NEPA) and the USFS’s interpretation of that act. The USFS interpretation of NEPA requires a separate Environmental Impact Statement (EIS) to be completed prior to the aerial application of any herbicide on USFS land. Considering that the average EIS would cost the utility $150,000 to $200,000 to complete, it is impractical to do. In 2005 a conglomerate of various organizations petitioned the USFS to allow for aerial application of herbicide when necessary under local Forest Service environmental impact statements where the use of herbicides has already been approved. To my knowledge this request to modify the USFS position relating to aerial herbicide application has yet to be approved.

The second issue relating to the use of herbicides, particularly foliar, basal, cut stump treatment etc. is consistent approval from USFS across multiple districts. Utilities might receive approval to use herbicides in one particular district, but have their use rejected in an adjacent area. In an attempt to rectify this situation a memorandum of understanding (MOU) between the USFS and utility companies was signed in the fall of 2006 to bring consistent application of USFS policy relating to herbicide use across all districts. It remains to be seen whether or not this MOU will have a positive impact to the consistent approval to use herbicides or not.

So for your particular situation, the first step is to contact your local USFS representative to receive the “approved” list of herbicides that you would be able to use on USFS property. If the ROW stretches across multiple districts, it would be wise to meet with all the district managers, have a well detailed plan of action of where and when you plan to use herbicides and get agreement in writing from the USFS as to their approval of your plan.

Certainly no utility wants to read in the headlines of the local paper or see on the television news that “XYZ utility is flexing its muscle, and refuses to halt plans to cut down Mrs. Jones prized silver maple.” Now I know you might be saying that you haven’t run into a Mrs. Jones like that so there is no way your company would ever trim or cut down trees of someone like that. You’re right, I haven’t met your particular customer, but chances are every utility has a Mrs. Jones, or in some case several Mrs. Joneses all across the system, but there is a way to reduce the number of refusals and/or complaints you receive.

In many cases, refusals can be avoided simply with the proper communication strategy in place. If you are relying on bill stuffers or small ads in newspapers as your primary communication strategy for property owners, then chances are you’re not utilizing your communications sources wisely. While bill stuffers are effective reminders if used regularly over a period of time, if you are serious about reducing complaints and communicating better with your customers, you’re going to have to utilize the most effective means of communication devised: face-to-face conversation. Yes, you need to put feet on the ground ahead of the tree crews and talk with your customer before the first chainsaw is ever fired up in front of their house.

Many utilities are finding a lot of success using third party pre-inspection personnel that identify the work needed, document the work through some sort of electronic means, and then communicate the necessary work with the property owner. This provides the property owner the opportunity to ask questions and have them answered by a professional utility arborist. I know many of you will say that your contractor’s foreman or general foreman already does this. While the foreman and general foreman may be great at managing tree crews safely and efficiently, they often don’t have the time, training or experience to implement an effective communication plan with your customers. A pre-inspection company that is independent of the tree contractor is the best choice because they bring utility arborists with the experience and training in utility vegetation management, and lend a tremendous amount of credibility to your program. Often, simply having this person communicate with your property owners about impending tree work will significantly reduce the number of refusals and complaints.

Finally, you should be consistent with the application of your specifications. Cutting special deals with a select few customers only creates more hostility for those individuals that didn’t receive that special treatment.

This is a fairly common problem. Utilities see their SAIDI (System Average Interruption Duration Index), SAIFI (System Average Interruption Frequency Index) and CAIDI (Customer Average Interruption Frequency) numbers degrading, tree-related outages on the rise, and they are not sure what to do. Often there is the frustration of “we are already spending millions of dollars on our program,” but you’re not seeing the expected results.

One of the best solutions to this dilemma is to hire a professional consulting firm to conduct a system assessment of the vegetation management program. The system assessment enables a utility to gain a 360-degree view of current conditions on the right-of-way, review and design a best practices management system, recommendation of an appropriate budget, design vegetation management specifications and recommended contracting strategy. The system assessment is similar to a “complete physical” of the right-of-way program and upon completion delivers a “play book” that a utility can implement to develop a cost effective program that improves reliability and maximizes the return on your investment.

Another consideration in the evaluation of a vegetation management program is the budget. I once had a manager of a utility say to me, “The trees don’t know you just cut the budget; and they should stop growing.” With vegetation management it is one of those expenditures where it is either “pay me now” or “pay me a lot more later.” In general terms, it is often a wise investment to focus your program on removing small trees and brush in and next to the right-of-way. This investment makes sense because it is much more cost effective to remove a smaller tree or area of brush, than to defer the work allowing the brush or trees to grow larger, hence the “pay-me-now or pay-me-a-lot-more-later”.

Finally, you should have the right team in place to manage the budget and implement the recommendations outlined in the system assessment. This team should have the technical skills and experience in utility vegetation management. These positions can be internal employees or contracted to a third party with expertise in utility vegetation management.