Rights-of-WayVegetation Guidelines

October 7, 2009

About us

Conco Line Clearing is wholly owned subsidiary of Conco Services Corp and is headquarter in Verona, PA. Our company has many competitive advantages that have been developed over the years, but our people are by far the most important. We constantly strive to engage, motivate and develop our employees. Consequently, we have over 200 people focused helping our customers solve their problems.

Purpose

Conco Line Clearing’s purpose is to help customers with professional right-of-way clearing and vegetation management services in the most efficient and economical way. This includes providing right-of-way mowing, hand clearing, large tree clearing and side trimming in all kinds of terrain.

 

Rights-of –Way (ROW) Rights-of –Way (ROW) Vegetation Management:Vegetation Management: What is a right-of-way?What is a right-of-way?

A ROW is a non-possessory A ROW is a non-possessory interest to use real property in interest to use real property in possession of another person for possession of another person for a stated purpose. It is the right to a stated purpose. It is the right to use and access property for the use and access property for the purpose of transporting and purpose of transporting and distributing gas, oil, fuel, water distributing gas, oil, fuel, water and energy.and energy.

Right-of-way (cont’d)

A situation in which a parcel of land has a specific private owner, some other party or the public at large has a legal right to traverse that land in some specified manner.

The term likewise refers to the land subject to such a right. An easement is another example.

ROW reliability, accessibility and public safety are major concerns across all rights-of-way for controlling selected types of vegetation.

Management of nearly all ROWs share common objectives, including worker safety, reduced fire hazard and the ability to perform inspections and pipeline surveillance: PIG Digs, Test Station readings and Leak Surveys. There are many issues unique to each type of ROW.

Pipeline Inspection mandated by the Department of Transportation (DOT) and by proxy, the National Transportation Safety Board.

They have jurisdiction over all underground utility ROWs. The Federal Energy Regulatory Commission sets up the guidelines and regulates the gas and energy industry. This can be very confusing.  DOT Says that You must perform pipeline Inspection:

•Transportation Research Board (TRB) •Pipeline Safety Improvement Act 2002 (PSIA)•Research & Special Programs Administration’s •Pipeline & Hazardous Material Safety Administration (PHMSA)

FERC tells you how and when to inspect pipelines.TRB and FERC work in Conjunction

DOT mandates in section 195.705 of federal pipeline safety regulation 49 CFR part 195, requires that hazardous natural gas pipelines be patrolled to observe surface conditions on and adjacent to the transmission line right-of-way for indications of leaks, construction activity and other factors affecting safety and operation.

The frequency of these patrols are determine by;• Size of the line• Operating pressure• The class location• Terrain• Weather• Other relevant factors

Maximum Interval Between PatrolsCharacteristics of Area Consisting of 220 yards of 1-mile Length of Pipeline

At Highway and railroadCrossings

At All Other Places

Any location having fewer than 46 buildings intended for human occupancy

7.5 months; but at least twice each calendar year.

15 months; but at least once each calendar year.

Any location having 46 or more buildings intended for human occupancy or where the pipeline lies within 100 yards of a building

4.5 months; but at least fourtimes each calendar year.

7.5 months; but at leasttwice each calendar year

Any location where buildings with four or more stories above ground are prevalent

4.5 months; but at least fourtimes each calendar year.

4.5 months; but at least four times each calendar year.

Patrol Frequency for Natural Gas Transmission Pipelines

Transmission (Interstate)

Transmission ROW vegetation maintenance clearing cannot be performed more frequently than every three years, however, a corridor that does not exceed 10 feet in width can be maintained annually to facilitate leak detection surveys.

Additionally, transmission ROW routine vegetation maintenance may not occur between April 15th and August 1st of any year to minimize the potential for impacts on migratory bird species that may use the permanent right-of-way for nesting.

Distribution (Intrastate)

Distribution pipeline companies do not fall under the same restrictions. Although, they must patrol high-pressure lines quarterly they are not restricted on their vegetation mowing or clearing applications. This also applies to lower distribution lines that are patrolled annually and/or tri-annually and usually identified by the distribution company integrated management program.

The reason for this is, typically distribution companies are located in highly populated areas where ROWs must be identified on a more frequent basis to facilitate a safe distance from the population.

In addition, distribution ROWs are in far worse conditions than comparable transmission ROWs.

Recent TRB Study: Recommendation Highlights

1.RSPA/OPS should develop risk-informed land use guidance for application by stakeholders, i.e. Utility Co. & Land Owners.

2.The Process should include:

a) Collaboration of all stake holders

b) Persons with expertise in risk analysis, risk communication, land use management and developing regulation:

c) Be transparent, independent and peer reviewed &

d) Incorporate learning & feedback to refine the guidance over time

3.Pipeline Industries should develop practices for the specification, acquisition, development, and maintenance of pipeline rights-of-way.

Recommendation 3: Develop Practices for Maintenance of Pipeline Rights-of-way.  Specifically: Vegetation Management: Vegetation Management is the manual, mechanical and chemical control and/removal of vegetation located within a rights-of-way.

Control Methods:

Manual Control: Using hand held equipment such as string trimmers, chain saws, brush hooks, machetes, hoes, and shovels. These are usually sharp.

• Used for treating areas where obstacles prohibit other methods• Very Labor and time intensive.• Debris removal very time intensive.• PPE.• Climbing

Mechanical Control: using machines to control vegetation. Including:

•Mowers•Tractors with Brush Hogs•Hydro Axe•Jarraff•Chippers•Excavators

Chemical Control: using herbicides to plant growth regulators.

•Complex, difficult and require more precision than other forms of weed control.•More expensive short term, long term benefits have not been realized.•Very popular in Energized Transmission.•There is no single herbicide that can meet the needs of every weed situation.•Not popular with public and has not been welcomed well.

Standards & Scopes:

This is an example of a standard and scope that may illustrate the benefit value of consistent vegetation management program.

Including:•Units of measurement•Pricing •Deliverables & Scope of Work. Units of Measurement:•Lineal Feet or Mileage x Width•Square Footage•Per Job•Residential Work Pricing:•Cost/Ft•Cost/Sq Ft•Lump Sum•Large Tree Removal•T&M•Combination

Deliverables & Scope of Work: Mowing:Right-of-way (ROW) mowing activity consists of vegetation cutting/mowing that is openly accessible and navigable by brush hog tractor(s), with minimal hand cutting, from brush line to brush line, within an established and sequentially continuous ROW (60,50, 40,30,20, & 10). These items include the mowing, proper removal of brush, bushes and (less than 4” in diameter) to the edge of the established ROW to as near to ground level as possible with out removing the roots. Manual Mowing: Right-of-way (ROW) hand mowing activity consists of vegetation cutting/mowing that is not openly accessible and navigable by brush hog tractor(s), and must be done by hand, from brush line to brush line, within an established and sequentially continuous ROW (60,50, 40,30,20, & 10). These items include the hand mowing, proper removal of brush, bushes and (less than 2” in diameter) to the edge of the established ROW to as near to ground level as possible with out removing the roots 

Clearing:

Right-of-way (ROW) clearing activity consists of Mechanical or Manual vegetation cutting that exceeds the parameters set forth above in ROW mowing. This applies to ROW areas that have growth intersect with road crossings, stone walls and fences. Fence ROW Clearing is the manual cutting of brush, bushes & trees (greater than 2”but less than 10” in diameter) to the edge of the established ROW ((60,50, 40,30,20, & 10) to as near to ground level as possible with out removing the roots.

Tree limbs and brush four (4) inches in diameter or greater, shall be poled, cut in manageable lengths not exceed eight feet and will be stacked in piles for wild life access and habitat (Rowing). Debris Removal should always be indentified. 

Side Trimming:

Right-of-way (ROW) side trimming activity consists of vegetation cutting that is openly accessible and navigable by Jarraff(s) tree trimmers, with minimal hand cutting, from ground to sky, within an established and sequentially continuous ROW.

Specifically, ROW side trimming activity is the cutting and proper removal of all brush, tree limbs (6” or less) to the edge of the established ROW. All tree tops under four (4”) in diameter shall be ran over with the brush hog and cut up and scattered across the ROW. Tree limbs and brush four (4) inches in diameter or greater, shall be poled, cut in manageable lengths not exceed eight feet and will be stacked in piles for wild life access and habitat. 

Large Tree Removal:

Tree Diameter •10”-15”•15.1”-22”•22.1”-28”•28” +•Climbing•Residential 

Herbicide: Using chemical treatments. Applied:•Manually: Backpacks•Mechanically: Trucks, ATV’s Tractors•Arial Spraying  

Program:

1st Round Clearing: Mowing2nd Round Clearing: Side trimming3rd Round Clearing: Herbicide Treatment  

Summary:

A disciplined vegetation management program provide a safe operating area, positive public relations and compliance with government regulations.  

William PutmanConco Line Clearingwww.ConcoLineClearing.com

Tel: (412) 828-1166 x1003

Fax: (412) 826-8255

E-mail: wputman@concosystems.net