Vegetation Management on Federal Land

To EEI Vegetation Management Task Force Members:

A committee of VMTF members has been working on the issue of
vegetation on Federal lands for several months. The committee consists of Mike Neal
(AZ Public Service), Bob Bell (Public service of NM), Randy Miller(Pacificorp),
Rick Johnstone (Conectiv) and myself (American Electric Power). The purpose of
this message is to bring you up to date on this issue. I also would like to solicit your
comments on the proposed plans and on a proposal for a Memorandum of Understanding
with Federal agencies.

If your company has rights-of-way that cross Federal lands or if you
have attended previous VMTF meetings, you are aware that there is often a
disconnect between Federal agencies and electric utilities. As a result,
there are frequent delays and severe restrictions on the ability of
utilities to provide safe, reliable electric service to their customers.
Some other consequences have included power outages affecting
millions of people and at least one major wildlife.

On March 13, 2002, the committee met with representatives from the US
Forest Service, Bureau of Land Management, US Fish & Wildlife Service,
FERC, EPA and the National Rural Electric Cooperative Association at
EEI's office in Washington, DC. EEI's Director of Environmental Affairs,
Rick Loughery, moderated the meeting.

During the meeting we discussed the need for safe, reliable electric
service for our customers and stressed the implications on national
security. We emphasized that many of the goals of Federal land
managers are similar to utility vegetation managers: environmental stewardship,
sustainable management, biodiversity, etc. Finally, we detailed the
problems faced in dealing with various agencies.

The agency representatives were understanding and receptive to the message.
They pointed out that much of the problem in dealing with Federal
agencies results from decentralization. Because many decisions are made
locally, each land manager must be brought into the decision making process.
Many of them are professionals with a great deal of knowledge about their
fields,but know little about electricity and right-of-way vegetation
management.

Therefore, concepts such as clearance requirements, herbicides, etc.
are foreign to them. Consequently, each land manager has a different
concept about how vegetation should be managed on rights-of-way, resulting in
inconsistent and often ineffective policies.

It was decided to approach the problem by proposing a Memorandum of
Understanding with each agency that would establish a programmatic
approach to right-of-way vegetation management on Federal lands. The
Memorandum would stress the needs of electric utilities and their customers, our
commitment to IVM principles, clearance requirements, performance
standards, and the responsibilities of member companies and the
agency. A copy of the draft MOU is attached.

A second approach will be on local level education of Federal land
managers. An educational program would be developed that details the
needs and programs of electric utilities that would be used to train land
managers. The EPA has offered to partner with EEI in this effort.

Attached is the draft MOU that would be used as a template for
developing specific MOUs with each agency. The committee is interested in your
feedback regarding the plan going forward and on the MOU. So after
reviewing the draft, please send me your comments via e-mail. In
order that we can provide an update at the EEI business meeting during the ISA
Conference in Seattle, please send your comments by June 14, 2002.

Please note in the draft MOU: two illustrations were removed from the
text due to the large size of the file. The illustrations depict the
wire/border zone concept and the clearance distances from trees.
Thanks in advance for your comments. I look forward to seeing you at
the Task Force meeting in Seattle.

Lynn Grayson, Chairman
EEI Vegetation Management Task Force

view Memorandum of Understanding

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