El Paso Corporation

INTEGRATED VEGETATION MANAGEMENT PLAN

TENNESSEE GAS PIPELINE RIGHTS-OF-WAY in NEW JERSEY

Tennessee Gas Pipeline El Paso Corporation 8 Anngina Drive Enfield, Connecticut 06082

February 2011 TABLE OF CONTENTS Page

1. INTRODUCTION...... 1 2. GOALS AND OBJECTIVES...... 2 GOALS...... 2 OBJECTIVES...... 2 3. TARGET VEGETATION...... 3 IDENTIFICATION OF TARGET VEGETATION...... 3 POISONOUS PLANTS...... 3 4. INTEGRATED VEGETATION MANAGEMENT PROGRAM ...... 4 5. DESCRIPTIONS OF INTENDED VEGETATION MANAGEMENT METHODS...... 6 SPECIAL FERC GUIDELINES...... 6 CHEMICAL (HERBICIDE) CONTROL METHODS...... 6 MECHANICAL METHODS...... 10 6. IDENTIFICATION OF SENSITIVE AREAS AND PROPOSED CONTROL STRATEGIES...... 13 IDENTIFICATION OF SENSITIVE AREAS...... 13 CHEMICAL CONTROL STRATEGIES FOR SENSITIVE AREAS...... 14 7. OPERATIONAL GUIDELINES FOR APPLICATORS...... 15 8. REMEDIAL PLAN TO ADDRESS SPILLS...... 17 TYPES OF CHEMICAL SPILLS THAT REQUIRE ACTION...... 17 REQUIRED SPILL RESPONSE EQUIPMENT...... 17 INFORMATION SOURCES...... 17 9. LANDOWNER NOTIFICATION PLAN...... 19 10. CUSTOMER SERVICE...... 21 PROGRESS AND PERFORMANCE TRACKER/ISSUES LOG...... 21 CORE TEAM...... 21

EXHIBITS

1. FORM OF LANDOWNER NOTIFICATION LETTER

2. FORM OF PRE-WORK “DOOR HANGER”

3. FORM OF RIGHT-OF-WAY PROGRESS AND PERFORMANCE TRACKER

APPENDICES:

1. DIVISION-SPECIFIC COMPONENTS

A. PERMITS

B. HERBICIDE LABELS AND ADDITIVES

C. ALIGNMENT SHEETS SECTION 1: INTRODUCTION

The pipeline companies comprising El Paso Corporation’s Eastern Pipeline Group have established a nationwide Integrated Vegetation Management Plan (“IVM”) for use in conducting vegetation control along rights-of-way occupied by their pipeline facilities. El Paso’s goal is to establish and maintain a gas pipeline right-of-way that is reliable, accessible, and inspectable in support of El Paso’s mission: the efficient, uninterrupted delivery of natural gas.

Tennessee Gas Pipeline (“TGP”) is one of the five interstate pipelines that make up El Paso’s Pipeline Group. TGP is comprised of approximately 14,200 miles of pipeline that stretches from the Mexican border to Canada including over 56 miles of high-pressure natural gas pipeline easements and associated equipment in the State of New Jersey (see Figure 1). It maintains its pipeline in easements ranging from 50 feet in width on its laterals and up to 150 feet in areas of multiple pipelines (these pipeline rights-of- way hereafter referred to as “ROW”s).

Pursuant to the federal Natural Gas Act, 15 U.S.C. §§ 717 et seq., the federal Natural Gas Pipeline Safety Act, 49 U.S.C. §§ 60101 et seq., and the federal Hazardous Materials Transportation Act, 49 C.F.R., Part 192 (Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards), TGP is required to adopt and implement an ongoing Operations and Maintenance Plan for purposes of maintaining the integrity and safety of its pipeline facilities.

To facilitate compliance with 49 C.F.R., Part 192, Subpart L (Operations) and Subpart M (Maintenance), TGP conducts periodic vegetation maintenance activities on its permanent easements. TGP must maintain its easements: to allow for aerial and other types of surveillance of pipeline conditions, to enhance its Damage Prevention Program, to facilitate planned cathodic protection surveys, and to allow access for both routine pipeline maintenance and emergency repairs. Maintaining its ROWs free of encroaching vegetation that may impede visual and physical access to the pipeline is critical to this surveillance. TGP must also comply with all applicable federal regulations including, but not limited to: The Endangered Species Act, The Migratory Bird Treaty Act, all applicable Federal Energy Regulatory Commission (“FERC”) standards, Federal Occupational Safety and Health Act (“OSHA”) regulations, and Environmental Protection Agency (“EPA”) regulations. In New Jersey, TGP must also comply with New Jersey Pesticide Regulations NJAC Title 7 Chapter 30, New Jersey Freshwater Wetland Protection Act Rules NJAC 7:7A, and Highlands Water Protection and Planning Act NJAC 7:38

Historically TGP has maintained its ROW in New Jersey by a 3 to 5 year mowing cycle, but now is initiating an IVM program. The program should lessen equipment disturbance and habitat alteration, increase efficiency, and increase the treatment cycle interval.

1 SECTION 2: GOALS AND OBJECTIVES

As part of its ongoing commitment to public safety, TGP conducts a Right-of-Way Vegetation Management Program that uses a variety of vegetation control methods, including tree cutting, mowing and/or herbicide application.

Goals of the Vegetation Management Program include the following.

 To establish a long-term, Integrated Vegetation Management (IVM) Program that takes advantage of technological advances and cost savings opportunities, all aimed at improving the effectiveness of TGP’s ROW maintenance processes. TGP intends to utilize herbicide application, where appropriate, as the predominant method of vegetation control in the future.

 To make the IVM Program environmentally responsible, legal, safe and flexible in order to accommodate unique situations and the need to use more appropriate techniques as they become known (in accordance with new regulations and/or scientific advances).

 To provide guidance for both TGP and contract personnel and to serve as a communication link for state and municipal officials, property owners, abutters and the public-at-large.

OBJECTIVES

Objectives of the Vegetation Management Program include the following.

 To maintain safe, reliable, functioning pipelines that comply with all applicable laws, rules and regulations.

 To control vegetation that impedes inspections or interferes with the ability to access the ROWs for maintenance or emergencies.

 To encourage stable early successional ecological communities of primarily lower growing grasses and forbs.

 To encourage the establishment of wildlife habitat that does not interfere with the primary function of the pipelines.

 To control invasive and poisonous plant species as required per employee concerns, construction permits, or in cooperation with regional invasive plant control strategies.

 To promote positive relationships with property owners, abutters, state and municipal officials, contractors, and the public.

2 SECTION 3: TARGET VEGETATION

Most woody vegetation interferes with the safe, efficient and legal operation of a pipeline and restricts the creation and maintenance of an easily recognizable ROW. According to Title 49, Part 195.146 of the Federal Code of Regulations, TGP must regularly patrol its pipeline by ground and/or aerial inspections. Tall, dense vegetation impedes the detection of leaks and other potential problems; the roots of large woody plants interfere with pipeline anti-corrosion coatings; and woody vegetation obstructs the visibility of and access to valve sites, pipe corrosion test stations, mile marker posts, and other pipe location markers. The need to identify and reach these sites quickly is vital, especially during an emergency situation. Therefore, TGP’s goal is to maintain a primarily early successional herbaceous vegetation community across the width of its entire ROW, and where not possible due to permit restrictions, a minimum ten-foot width of herbaceous vegetation centered over the pipeline.

IDENTIFICATION OF TARGET VEGETATION

Target vegetation will be identified and removed by professional, experienced, trained, licensed and certified contractors. The primary target vegetation on TGP's ROWs includes, but is not limited to the following.

 Trees, such as aspen, beech, birch, cherry, maples, oak and pines

 Shrubs, such as dogwood, high bush blueberry, buckthorn, honeysuckle, mountain laurel, speckled alder, sumac, willow, viburnum and witch hazel

 Woody vines and other vegetation, such as bittersweet, greenbrier, wild grapes, and blackberry

 Poisonous plant species, such as poison ivy and poison sumac.

Lower-growing woody vegetation, grasses, and herbaceous vegetation that compete with taller woody vegetation generally do not interfere with the function and inspection of the pipeline, and create a favorable habitat that is beneficial to both people and wildlife. These lower-growing species include, but are not limited to: low-bush blueberry, huckleberry, sweet fern, grasses, ferns and wildflowers.

POISONOUS PLANTS

TGP personnel are required to maintain cathodic protection along the buried steel pipelines. Among other duties, this entails regular maintenance of cathodic protection installations and appurtances, including rectifiers, magnesium groundbeds and test stations. The plant communities around many of these installations and appurtances are dominated by poison ivy, which is resulting in increased first aid cases and OSHA reportable incidents.

Each identified hazardous location of poisonous plants requires applications of herbicides with backpack or hand-held equipment along the ROW access path and up to 400 square feet surrounding the cathodic protection device.

TGP's goal is to reduce poisonous plant species populations to a level that does not present a significant injury risk to its personnel, while encouraging non-hazardous, native vegetation to become dominant.

3 SECTION 4: INTEGRATED VEGETATION MANAGEMENT PROGRAM

This IVM Program takes into consideration various factors involved in the maintenance and operation of pipeline ROWs. It reflects TGP’s intent to minimize adverse effects to the environment, while supporting TGP’s primary obligation to deliver natural gas in a safe and dependable manner. The IVM Program is summarized in Table 1 below.

Table 1 Integrated Vegetation Management A combination of Mechanical, Chemical & Natural vegetation management techniques that promote long-term control with minimal impact on non-target organisms

Mechanical Control Chemical Control Natural Control The physical removal of the stem and branch of The selective use of herbicides applied to The science of working in concert with the stages of target vegetation by cutting, chopping or mowing, the foliage, stems and/or root zone of target vegetation plant succession and interspecies competition to limit usually leaving the root system intact to suppress growth and acheive root control the establisment of taller undesirable vegetation

TGP’s experience is that sole reliance on cutting, mowing and other mechanical methods (e.g., excavation, hand-pulling) of vegetation control usually results in only temporary control, encourages increased stem counts of woody vegetation, and may contribute to the spread of certain invasives, especially those species capable of reproducing from rhizomes (creeping underground stems). Soil disturbance associated with mechanical grading, excavation, or even mowing equipment can provide a good opportunity for stem, root fragments, and seeds of invasives to advance into new sites. Additionally, mowing produces an immediate loss of wildlife habitat due to its non-selective nature.

Mechanical vegetation management is currently performed on a 3 to 5 year cycle, but does not meet the goal of maintaining a primarily herbaceous layer of vegetation directly over the pipeline. In certain areas, more frequent mowing is required to control woody vegetation and promote a dominant herbaceous layer, thus increasing potential impacts of erosion and compaction from heavy mowing equipment , and potential accidental releases of hydrocarbons from hydraulic systems.

The selective use of herbicides is the tool of choice to control woody plant resprouts, invasives, and poisonous plant species. There is little site disturbance associated with herbicide applications and the entire target plant, including the roots, is controlled, stopping their spread by re-sprouts and rhizomes. Selective application of herbicides to target species, as contrasted with mowing, does not produce an immediate loss of wildlife habitat.

All poisonous plant species are best managed by early recognition and intervention before a small intrusion becomes a large infestation. A quick response with appropriate control methods will reduce the likelihood of a severe invasion. When aggressive invasive plant root systems are controlled, other desirable native vegetation has an opportunity to reestablish dominance on the site, thus promoting natural control.

Natural control is the process of working with the biological cycles of plant succession and interspecies competition in order to lessen the dependence on chemical and mechanical controls. Since poisonous

4 plants are among the most aggressive vegetation species in the Northeast, herbicides are all the more important as a control method. Selective herbicide applications will promote natural controls and reduce the frequency and impact of treatment cycles, which will further reduce the potential negative impact ROW maintenance, has on the environment from solely mechanical methods.

At the sites where TGP plans to utilize more than mechanical controls as the direct method of vegetation management, herbicides will be used to encourage the development of natural controls and to reduce the negative impact of mechanical controls. These herbicide treatment cycles will be scheduled to sustain acceptable vegetation control at minimal application rates without jeopardizing pipeline operations. Using historical mowing records for pipeline segments, TGP is scheduling initial herbicide applications to begin the third growing season after mechanical mowing to provide the most effective treatment, with followup treatments on a three year cycle or until vegetation control goals are reached, and a longer interval is appropriate.

Herbicide applications minimize the personnel and equipment utilized, and their repeated impact on the environment. They permanently control re-sprouts and increase the length of time between treatment cycles by reducing the recurrence and density of target vegetation. Selective herbicide applications are much less destructive than mowing to nesting habitat and the vegetative cover necessary for food and concealment by wildlife.

The use of modern herbicide application equipment and restrictions to apply herbicides in the most judicious manner practicable further minimizes environmental impacts. Herbicides, particularly when applied selectively by low-volume methods, dry quickly on the plant surface, thereby significantly minimizing the potential for dermal exposure. The use of anti-drift additives that can be adjusted to accommodate changes in wind velocity in all foliage applications further limits the likelihood of unintentional exposure to non-target organisms.

Applications will not be made in situations when there is a reasonable expectation that herbicides will drift from the target, or during measurable precipitation. Herbicides will not be applied to target vegetation standing in or near surface water, or in other circumstances that might materially jeopardize the health and safety of humans, animals, or the environment. Restrictions on the use of herbicides near sensitive areas are further detailed in Section 6.

Finally, professional, certified and licensed field personnel will carry out all vegetation management activities in strict compliance with all applicable federal, state and local laws, rules, and regulations.

5 SECTION 5: DESCRIPTIONS OF INTENDED VEGETATION MANAGEMENT METHODS

Details of TGP’s intended vegetation management methods are provided in the following text. The methods include both chemical (herbicides) and mechanical techniques. Individual techniques described include: foliar treatments, pre-emergent treatments, low volume basal treatments, cut stump treatments, hand cutting, mowing, and selective trimming.

The treatment methods used on any given ROW are based on site sensitivity, regulatory mandates, target species composition, density and height, site access, topography, and treatment methods. The goal is to achieve a long term, low maintenance IVM program.

SPECIAL FERC GUIDELINES

Maintenance on pipeline ROWs under FERC certification are restricted by conditions of the certification. FERC’s Wetland and Waterbody Construction Mitigation Procedures from certain original pipeline certifications restrict mowing in sensitive areas, such as wetland and waterbody crossings. In New Jersey, these FERC restrictions apply to the following pipelines: 300-2. In ROWs crossing wetlands for these pipelines, TGP must restrict vegetation maintenance over the full width of the permanent ROW as follows.

 A corridor centered on the pipeline and up to ten feet wide can be maintained in a herbaceous state.  Trees within fifteen feet of the pipeline and greater than fifteen feet in height may be selectively cut.  For waterbody crossings, TGP must limit vegetation management to allow a riparian strip at least twenty-five feet from the mean high water mark to revegetate with native plant species across the entire ROW. Additional FERC restrictions include the following.  ROW access will be through the use of established roadways or access points whenever possible.  Permission to enter a ROW by any other means must be obtained from the landowner.  FERC Upland and Wetland Construction Mitigation Proceedures from certain original pipeline certifications restrict routine vegetation management between April 15th and August 1st of each calendar year. The following Tennessee Gas Pipelines are not subject to the FERC restrictions except for Land Owner Notification: 300-1. CHEMICAL (HERBICIDE) CONTROL METHODS

For purposes of this IVM, TGP contractors will utilize the following four chemical control treatment methods.

 Foliar  Pre-emergent  Basal  Cut and Stump Treatment

The applied mixtures will consist of herbicide(s), adjuvants, carriers and additives. The actual choice of application methods depends upon many variables, including but not limited to: site sensitivity, regulatory mandates, target species composition, density and height, topography, and access.

The following general guidelines will be observed for all herbicide applications.

6  Herbicide applications follow all restrictions in New Jersey Pesticide Regulations NJAC Title 7 Chapter 30, New Jersey Freshwater Wetland Protection Act Rules NJAC 7:7A, and Highlands Water Protection and Planning Act NJAC 7:38.

 All herbicide applications will be performed by experienced, trained vegetation management personnel with current New Jersey Certified Pesticide Applicator Licenses and must be able to identify target and non-target species.

 The contractor is responsible for the proper disposal of all excess materials and solutions in accordance with all applicable Federal and State laws, regulations and guidelines.

 Mixing will take place according to all restrictions contained in NJAC Title 7 Chapter 30 and according to the chemical labels.

 Label restrictions for use of herbicides will be followed.

 Herbicide applications will follow the target vegetation and timing restrictions in the Pursuant to FERC Wetland and Waterbody Construction Mitigation Procedures, no applications within 100 feet of a wetland or surface water unless authorized by a permitting agency, or state regulation. The most restrictive requirements will be followed.

 Herbicides will not be applied to active pasture land unless arrangements are made with land owners to move livestock to an alternative location.

 Sensitive Area control strategies from Section 6, Table 1 will be followed at a minimum unless more restrictive requirements from pesticide label or permit apply.

FOLIAR TREATMENTS:

Foliar application is the application of herbicides to fully developed leaves, stems, needles or blades of a plant. The herbicide concentrate is usually mixed or diluted with water and applied as a uniform spray over the plant’s foliage. Two types of equipment for foliar treatments are used: back pack and vehicle mounted. Both treatments use low pressure, below 60 pounds per square inch (psi) at the nozzle, for applications. The application period usually extends from early June through the beginning of leaf abscission in early fall when not restricted by regulations. This is generally the most economical and effective method, particularly in medium and high brush density situations. It is also the best technique to control noxious and poisonous vegetation that presents a hazard to inspection and maintenance crews.

Low Volume Backpack Foliar Techniques utilize hand-operated pumps or motorized, backpack sprayers. The motorized, backpack sprayer produces an air current that delivers the herbicide mixture in small droplets from the portable three to five gallon spray tank to the target vegetation. Both techniques only require the applicator to dampen or lightly wet the target leaf area not to the point of runoff. This minimizes the amount of excess herbicide drip from target species onto desirable ground cover. Low volume applications also eliminate the need to bring heavy equipment on the ROW for the transportation of large quantities of herbicide solution. In regulated wetland areas, aquatic approved herbicides will be used (See Section 6, Table 1).

Low Volume Hydraulic Foliar Techniques generally utilize a 100-500 gallon hydraulic sprayer mounted on a truck, tractor or tracked vehicle equipped with hand-held spray guns. The 7 herbicide mixture is directed at specific vegetation or broadcast for uniform coverage. Specially designed showerhead-type nozzles reduce spray volumes and limit droplet fines thus reducing the potential for spray drift off-target. These nozzles deliver effective spray coverage at relatively low spray pressures of 60 psi and less. This technique is capable of delivering uniform, penetrating spray coverage to dense, tall, target vegetation. It is particularly useful for sites where total vegetation control or pre-emergent herbicide applications are required for fire safety, such as at compressor stations and valve sites or for initial treatment of invasive plants. In regulated wetland areas, aquatic approved herbicides will be used (See Section 6, Table 1).

The following guidelines are observed in all foliar applications.

1. Anti-drift Agents are added to the mix or solution in all foliage applications to reduce the potential of herbicide drift beyond target vegetation. Drift control agents reduce the break-up of sprays into fine droplets and offer increased selectivity, leaf tissue penetration, and herbicide deposition on target plants.

2. Foliar applications are not used in the following situations.

 Target vegetation is over twelve feet in height.  Target vegetation is in surface water.  During periods of wind, which are strong enough to bend the tops of the main stems of tree species on the ROW.  During periods of moderate or heavy rain fall (where leaf runoff can wash the herbicide off the target plants).  Where landowner agreements preclude their use.

3. Foliar treatments are effective in light mist conditions.

4. Foliar treatments are an effective method to convert ROWs previously maintained by mechanical only methods by treating resprouts after a preparatory mowing operation.

PRE-EMERGENT TREATMENTS:

Pre-emergent treatments involve the use of non-selective pre-emergent herbicides that prevent seeds from sprouting using the same equipment and guidelines described in the foliar treatments above. Pre- emergent applications are used where season long vegetation control requires “vegetation-free conditions,” such as around valve sites, meter station, compressor stations, and cathodic protection installations. By preventing the growth of vegetation, pre-emergent applications reduce the amount of applied herbicides and the number of applications necessary in a season. This method is used from the early spring to early fall. See Section 6, Table 1 for restrictions in sensitive areas.

8 CUT AND STUMP TREATMENTS (CST):

Cut and stump treatment involves the application of an herbicide mixture diluted in water or a non- freezing agent to the cut surface of a stump immediately following or during a cutting operation to prevent resprouts and root suckering. To obtain root control, it is only necessary to treat the phloem and cambium tissue, regardless of the stump diameter. Treatment should, however, ideally be made to freshly cut stumps. Application equipment includes low-volume, backpack, hand-pump sprayers; hand held squirt bottles; paintbrushes, or sponge applicators. In regulated wetland areas, aquatic approved herbicides will be used (See Section 6, Table 1.)

The following guidelines are observed in all CST applications.

1. CST is used for the following reasons/situations.

 To reduce the need to re-treat the same vegetation by controlling the root system.  To reduce the visual impact of vegetation management treatments.  For its selectivity to protect desirable vegetation.  At any time of the year.  To prevent resprouts of vegetation over twelve feet in height cut in preparation for a foliar application.  To chemically treat target vegetation in sensitive areas where other methods are not possible.

2. CST is best avoided under the following conditions.

 During the season of high sap flow.  In moderate to heavy stem densities.

3. CST is not used under the following conditions.

 In moderate to heavy rains.  In deep snow that prevents hand cutting (see Hand Cutting below).  In chemical restricted sensitive areas.

LOW VOLUME BASAL TREATMENT:

Low volume basal is the selective application of an herbicide, diluted in specially formulated oil, to wet the entire lower twelve to eighteen inches of the main stem of target plants. Using a hand pump backpack unit, the oil enables the herbicide solution to penetrate the bark tissue and translocate within the plant.

The following guidelines are observed in all Low Volume Basal applications.

1. Low volume basal treatments are extremely selective and used under the following conditions.

 When vegetation density is low.  In areas where extreme selectivity is necessary.  Any time of year, including in the dormant season when foliage, grasses and herbaceous plant are not obstructing the main stem.

9 2. Low volume basal treatments are not used under the following conditions.

 In moderate to heavy rains.  In deep snow that prevents treating the lower twelve to eighteen inches of the main stem of target plants.  In chemical restricted sensitive areas.  During spring sap flow.

MECHANICAL METHODS

Mechanical control methods include hand cutting, mowing, and side trimming. General and specific guidelines for the use of mechanical methods are provided in the following text.

The following guidelines are observed in all mechanical operations.

1. As much as possible, mowing and side trimming takes place in the late summer, fall or winter months to minimize ground disturbance.

2. Areas too saturated to support mowing equipment are hand-cut.

3. TGP's mowing contractors are expected to repair any rutting and utilize existing permanent stream crossings whenever possible.

4. All mechanical equipment is expected to be in sound operating condition.

5. Treatment crews will have petroleum spill kits available on site in the event of an incident.

6. Mechanical controls are used when conifers exceed six inches in height or are present in wetlands.

7. Mechanical controls are used in easement restricted areas and where landowner agreements preclude herbicide use.

HAND CUTTING:

Hand cutting involves the use of chain saws and brush saws to cut the stem and/or branches of plants. Hand cutting is used to remove hazard trees, remove target vegetation greater than twelve feet tall, to protect environmentally sensitive sites, and where herbicide use is prohibited. Hand cutting is also used on sites where terrain, target species size, or sensitivity renders mowing impossible or impractical. Hand cutting may be used at any time of the year.

The following guidelines are observed during hand cutting operations.

1. Target plants are cut as close to the ground as practical with stump height usually no higher than root swell.

2. All mechanical method targeted plants greater than six inches in diameter at breast height (DBH) shall be hand cut.

10 3. Cut stems/slash are piled and/or diced as follows.

 In areas of medium to heavy density target plants, slash is either left parallel to the ROW or in wind rows no greater than three feet in height along the edge of the ROW corridor.  In areas of very light to light density target plants under six inches DBH, slash is diced where it falls so that it lies as close to the ground as practical; the diced slash should not exceed two feet in height.  Larger trees are limbed and diced.  A twenty-foot-long fire break is maintained for every 100’ of wind row.  Slash will not be left in or on waterways, fence lines, stone walls, trails or roads, or in a manner that would permit it to wash into these areas.  Slash from yards or recreational sites will be chipped or removed to adjacent areas for disposal.

4. The placement of cut brush/slash must comply with applicable state and local Fire Marshall’s regulations.

5. All cut cherry is removed from active pastures.

6. Chipping is used at sites when dicing or piling are prohibited, impractical, or near residences.

7. Wood chips will be removed, or scattered uniformly over the site at depths not exceeding four inches.

8. Where applicable, FERC Wetland and Waterbody Construction Mitigation Procedures restrict hand cutting in areas, such as wetland and waterbody crossings, as follows.

 Within the twenty-five foot wide riparian strip at waterbody crossings (from the mean high water mark), all woody vegetation may only be removed in a 10-foot wide corridor centered on the pipeline.  Trees within fifteen feet of the pipeline and greater than fifteen feet in height may be selectively cut.

MOWING:

Mowing is the cutting, severing or shattering of vegetation by large rotary or flail mowers. Heavy-duty mowers, usually ranging from five to eight feet wide, are typically mounted on large four-wheel drive rubber tired tractors or tracked vehicles; these vehicles may weigh several tons each. Mowing may be used at any time of the year except when snow precludes operations.

The following guidelines are observed during mowing operations.

1. Mowing height is no higher than six inches unless required by regulation.

2. Operators must perform daily integrity inspections of hydraulic systems and carry petroleum spill control equipment on the mowing machines.

3. Operators must use designated access to ROW.

4. Mobile equipment shall not intrude into residential lawn areas.

11 5. Operators must permanently repair rutting and scarification of the ROW.

6. Mowing is used on sites under the following conditions.

 Where herbicide use is prohibited by regulatory or easement restriction(s).  Where a large number of target plant stems have exceeded maximum control density and hand cutting is inefficient and expensive.  Where access is required in the short term in areas impeded by high woody vegetation density.  Where terrain, site size and sensitivity permit the efficient use of the equipment.

7. To reduce the impact to non-target organisms including food, cover and nesting sites for migratory wildlife, TGP schedules routine mowing activities after the primary nesting season (generally from mid-April to mid-July) except during emergencies or under extenuating circumstances.

8. All mechanical method target species greater than six inches DBH shall be handcut not mowed.

9. Hand cutting will be used in areas where mowing is restricted by terrain conditions such as steep, rocky sites, wet soils, residential lawn areas, or next to obstructions such as stone walls and fence lines.

10. FERC Wetland and Waterbody Mitigation Procedures from certain original pipeline certifications may also restrict mowing in sensitive areas, such as wetland and waterbody crossings, as described in the following.

 Within the 25-foot wide riparian strip at waterbody crossings (from the mean high water mark), all woody vegetation may only be mowed in a 10-foot wide strip centered on the pipeline.  No mowing within wetlands except for a 10-foot wide strip centered over the pipeline.

11. Care must be exercised to insure the safety of the general public as mowing brush can throw large chips and debris great distances from the cutting equipment, and, when appropriate, requires employing someone to prevent people and animals from coming too close to the work site.

SIDE TRIMMING:

Side trimming is the cutting or removal of encroaching tops and/or branches of trees growing on or near the ROW in such a manner that they cause a hazard, hamper access, and/or impede visual inspections. This management technique is usually accomplished by the use of an aerial lift mounted on a street or off- road vehicle, although, tree climbing is sometimes employed in situations where terrain prevents the passage of equipment. This method is useful in maintaining the edge definition of the ROW corridors, and provides for easier inspections of vegetation conditions during aerial patrols. All trimming activities are performed in accordance with proper arboriculture practices and in compliance with all applicable regulations in order to insure the health and aesthetic value of the trees.

12 SECTION 6: IDENTIFICATION OF SENSITIVE AREAS AND PROPOSED CONTROL STRATEGIES

Sensitive Areas are "any areas within rights-of-way in which public health, environmental or agricultural concerns warrant special protection to further minimize risks of unreasonable adverse effects." They include, but are not limited to, the following areas: water supplies, surface waters including wetlands, cultural sites, and wildlife areas. Identified sensitive areas are listed in Division-specific IVM Plans, which include marked up pipeline alignment sheets, permits, and GIS mapping. This information is communicated to the vegetation management contractor prior to work on the pipeline ROW or facilities.

IDENTIFICATION OF SENSITIVE AREAS Sensitive areas can be divided into two categories that help the individuals assigned the task of identifying and treating them in the field; the categories are: “readily identifiable in the field” and “not readily identifiable in the field.” Readily identifiable in the field areas will be treated, identified and when appropriate, marked according to all applicable restrictions. Areas not readily identifiable in the field will likewise be treated and marked when appropriate, but they are identified by the use of data marked on maps and collected in the permitting and notification processes.

Sensitive areas usually identifiable in the field, include but are not limited to: surface water, some private and public water supplies, wetlands, and inhabited and agricultural areas. It should be noted that registered organic farms are not easily identifiable in the field, but they are identified in TGP’s abutter notification process.

Sensitive areas not usually identifiable in the field, include, but are not limited to: designated public surface water supplies, public ground water supplies, some private drinking supplies, and habitat of state- listed species.

As appropriate, therefore, sensitive areas will be identified and marked in the field by either TGP personnel, trained and experienced vegetation management contractor personnel, and/or by individuals trained in the identification of sensitive areas.

The following resources help in the identification of sensitive areas.

1. TGP’s pipeline alignment sheets, maps, records and institutional knowledge.

2. TGP permitting documents, including original construction permits.

3. GIS mapping layers and aerial photographs available through New Jersey GIS, and others.

4. Board of Health maps and lists of identified private wells.

5. Consultations with U.S. Fish &Wildlife Service and NJDEP Endangered Species Program.

6. Correspondence and meetings resulting from TGP's abutter notification procedure.

7. A point person who verifies identified sensitive areas and any additional areas that may require special precautions.

8. USGS topographical maps.

9. Information from contractor’s knowledge and records. 10. Treatment crews are required to have the following references on the job site to help identify sensitive areas.

13  Topographical maps (electronic or paper)  Copy of permits  Pipeline alignment sheets  Any additional information that may become available.

CHEMICAL CONTROL STRATEGIES FOR SENSITIVE AREAS

Identified sensitive areas are listed in Division-specific IVM Plans, which include marked up pipeline alignment sheets, permits, and GIS mapping data. This information is communicated to the vegetation management contractor prior to work.

A key strategy to minimize off-target damages to sensitive areas is to designate buffer zones around these areas. The following Table 1 lists the minimum buffer zones around sensitive areas; these zones may be increased per permit or label restrictions.

TABLE 1 – CHEMICAL CONTROL STRATEGIES FOR SENSITIVE AREAS

SENSITIVE AREA MINIMUM BUFFER ZONE CONTROL METHOD Public Ground Water Supply 400 feet No chemical allowed well Public Surface Water Supplies 100 feet No chemical allowed Private Drinking Water Supply 100 feet No chemical allowed well 25 feet (LV Hydraulic) Surface Waters* 10 feet (LV Backpack) No chemical allowed 5 feet (CST) Low-volume backpack foliar, Surface water buffers apply CST,Vehicle mounted LV where water present. Treatment Wetlands* hydraulic in wetlands per approved Recommended aquatic wetland permit. herbicides 100 feet (LV Hydraulic, LV CST Habitated Areas Backpack, LV basal) CST 50 feet (LV Hydraulic, LV Agricultural Areas Recommended aquatic Backpack, LV basal) herbicides Endangered and Threatened Per specific agency Per specific agency Species recommendations or permit recommendations or permit *FERC restrictions require minimum 100 feet buffer and no chemicals allowed without permit.

Reference sources: Treatment crews are required to have the following references on the job site to help identify sensitive areas.

 Copy of division-specific IVM Plan  Maps provided by the contractor  Permits  Pipeline alignment sheets  Any additional information that may become available

14 SECTION 7: OPERATIONAL GUIDELINES FOR APPLICATORS

TGP’s contract with its independent contractors for vegetation management requires that contractors comply with all applicable federal and state laws and regulations. This includes, but is not limited to, applicable OSHA and DOT regulations. General operational guidelines are as follows.

1. Both the contractor and TGP are responsible for conducting vegetation management activities in a professional, safe, efficient manner, with special attention paid toward minimizing environmental impacts.

2. The contractor must provide qualified, state licensed and certified personnel to apply herbicides to TGP’s ROW. “Qualified” mean personnel who have been trained to recognize and identify target and non-target vegetation and to be knowledgeable in the safe and proper use of both mechanical and chemical vegetation management techniques.

3. Vegetation management crews will exercise care to prevent non-target organisms from being unreasonably affected by the application of herbicides.

4. Herbicides are only applied in a safe and judicious manner, in compliance with applicable state and federal pesticide regulations.

5. Herbicides are to be handled and applied only in accordance with the label instructions. Contractors will strictly adhere to all mandated safety precautions directed toward the public, the applicator, and the environment. While performing treatment on TGP’s ROWs, herbicide applicators will wear any and all personal protection equipment enumerated on product labels.

6. Applicators will at all times exercise good judgment and common sense during herbicide treatment activities, and will immediately cease the operation if adverse conditions or other circumstances warrant.

7. Herbicides are not applied during the following adverse weather conditions.

 During high wind velocity.  Foliar applications during periods of dense fog, or moderate to heavy rainfall.  Foliar applications of volatile herbicides during periods of high temperatures (90 plus degrees Fahrenheit), and low humidity.  When deep snow (i.e. 6” plus or ice frozen on stem or stump) prevents adequate coverage of target plants to facilitate acceptable control.

8. The contractors’ foreman or senior member of the crew must complete daily vegetation management reports. These forms will be submitted to TGP and require the following information.

 Date, name and address of vegetation management contractors.  Identification of site or work area.  List of crew members.  Type of equipment and hours used, both mechanical and chemical.  Method of application.  Target vegetation.  Amount, concentration, product name of herbicide(s), additives, diluents, and EPA registration numbers.  Weather conditions.  Notation of any unusual conditions or incidents, including inquiries from the public.

15 9. All equipment used for vegetation management programs must be maintained in good working condition, and shall be of adequate design and functional ability to produce the professional quality of work that TGP requires.

10. All vehicles shall be equipped with absorbent material or pads in the event of a spill.

11. The vegetation management program must result in a 95% control of all target species. If less than the desired control is achieved, the contractor may be held responsible to re-treat or remove the remaining vegetation to TGP’s satisfaction.

12. The owner(s) of the land, will at all times be treated with courtesy and respect. Permission must be obtained if entering the ROW from private land, and precaution and common sense shall be exercised when moving vehicles and equipment. All bar-ways and gates shall be immediately closed, and care must be exercised to prevent the rutting or destruction of roadways or any other form of access. The treatment crew will not leave litter of any kind on the ROW or adjoining land.

13. When addressing inquiries or complaints from a landowner or other concerned person, the foreman of the ROW crew will explain the program in a polite and professional manner. If there is a demand from the landowner that the vegetation maintenance cease, then the foreman should remove the crew and equipment off the property, and the TGP representative should be contacted as soon as possible and advised of the situation. The crew will not return to that location until given clearance by TGP.

16 SECTION 8: REMEDIAL PLAN TO ADDRESS SPILLS

TGP’s contractors are responsible for all aspects of ROW applications, including containment, cleanup and reporting of chemical spills or accidents. Contractors are expected to immediately contact TGP upon discovery of a release of chemicals to the environment. TGP expects that all contractors will comply with the following minimum standards, while maintaining their own expertise in this area.

TYPES OF CHEMICAL SPILLS THAT REQUIRE ACTION

Any chemical outside of its proper container or intended use can be considered a spill. Chemicals include, but are not limited to, the following items.

 Herbicides  Bar and Chain Oil  Motor & Hydraulic Oil  Diesel Fuel  Gasoline

REQUIRED SPILL RESPONSE EQUIPMENT

Spill response equipment is required on the job site. As a minimum, the treatment crew should have the following items available on the job site.

 Product Material Safety Data Sheets (MSDS) and product labels  Appropriate absorbent material such as “speedi dri” or “soak up”  Shovel  Broom  Flagging  Leak proof container  Heavy-duty plastic bags

INFORMATION SOURCES

Product information sources and emergency contacts shall be available. These sources include the following.

Technical Reference Materials:

 Product Label  Product Material Safety Data Sheet (MSDS)  Product Fact Sheet, if available

Manufacturers:

MANUFACTURER TELEPHONE NUMBER SPECIAL INSTRUCTIONS BASF Corporation (800) 424-9300 Chemtrec in case of emergency DOW (800) 424-9300 Chemtrec in case of emergency Nufarm (800) 424-9300 Chemtrec in case of emergency

State Agencies:

STATE AGENCY TELEPHONE NUMBER SPECIAL INSTRUCTIONS NJDEP (877) 927-6337

17 18 Emergency Services:

EMERGENCY SERVICE TELEPHONE NUMBER Clean Harbors 1-800-645-8265

19 SECTION 9: LANDOWNER NOTIFICATION PLAN

Affected landowners will be notified via mass mailing prior to commencing herbicide application. The mass mailing address list will be generated by DOT Compliance Services – based on a 600 ft. corridor (300 ft. on either side of the pipeline). The form of Landowner Notification Letter is attached hereto as Exhibit 1.

Landowners will be asked to review the letter and an attached information sheet carefully and contact TGP via toll-free number or email within 15 days of receipt should they have concerns or objections. A contract answering service will receive all initial calls from landowners responding to the letter and shall follow the steps outlined below.

 Collect from caller

Address

County

Best time to call

Description of concerns

 Compile information

Excel spreadsheet

 Convey to landowner

Email to Property Rights

Property Rights (Houston) will receive concerned landowner information (Excel spreadsheet) from answering service and post it to a master tracking log. Property Rights (Houston) will distribute the information to the appropriate Field Property Rights Specialist for handling.

Field Property Rights Specialists will coordinate landowner response activities and conduct proper follow-up using the resources/steps outlined below.

. Resources

 Field Property Rights Specialists (primary caller)

 Core Team members (if requested by Field Property Rights)

 Local operations supervision (if requested by Field Property Rights)

20 . Approach

 Answer questions/educate

 Obtain permission or refusal

. Communication Methods

 Phone call

 Face-to-face (as needed)

. Documentation

 Master log will be updated to reflect all results of landowner contacts:

o Field Property Rights Specialist, or

o Property Rights in Houston, or

o Core Team (as appropriate)

 Pre-work review of Master Tracking Log (Property Rights and Core Team) to address unresolved issues as follows.

. Landowners who have not been reached (blanks in the log)

. Landowners who have been contacted but additional follow-up is needed

. Landowners who have denied permission to use herbicides

 Core Team and Field Property Rights Specialist identifies “no herbicide use” areas

o Core Team communicates “no-herbicide use” areas to Area Operations Manager and contractor prior to and during pre-job meetings

 Annual Review Landowner Notification Process – Property Rights and Core Team

Prior to the spraying operations, the Contractor will distribute “door hangers” on all residents within the 600 ft.-wide corridor informing the residents of the upcoming work. The form of the pre-work door hanger is attached hereto as Exhibit 2, which will be revised as needed to be pipeline subsidiary-specific (Tennessee Gas Pipeline, Southern Natural Gas Company, etc.)

21 SECTION 10: CUSTOMER SERVICE

PROGRESS AND PERFORMANCE TRACKER/ISSUES LOG

Once spraying operations commence, Core Team members will field calls from Operations supervision or landowners in their respective divisions and log information on a SharePoint-housed tracking spreadsheet. Contractor’s Project Manager will have ready access to the online tracker and will be notified immediately for all items requiring a response from the contractor. Target response time for follow-up calls is 24 hours.

Core Team (division-specific) will notify Field Property Rights Specialist about any calls pertaining to landowner issues. Contractor’s Project Manager has ultimate responsibility for responding to all calls from landowners and Operations supervision.

Core Team will review the tracker monthly and liaison with the Contractor’s Project Manager to ensure all landowner and contract performance issues are being addressed, resolved and documented in a timely manner.

CORE TEAM

TGP intends to utilize the Core Team to manage the IVM Program and related processes on an ongoing basis.

22 EXHIBIT 1 – FORM OF LANDOWNER NOTIFICATION LETTER

{ Insert Date}

Dear Pipeline Neighbor,

Did you know that vegetation on a pipeline right-of-way has the potential to increase the likelihood of damage to critical natural gas transportation facilities? As part of our ongoing commitment to public safety and to our vision of being the Neighbor to Have across our operations, { Insert Name of Pipeline Subsidiary} ({ Insert Pipeline Subsidiary Contraction, e.g., “TGP”, “SNG”…} ) uses a variety of vegetation control methods, including tree cutting, mowing and the application of herbicides as part of our comprehensive right-of-way management program. We’re writing today to tell you about the program and ask for your help.

Our program has three key objectives:

 Prevention. Keeping our right-of-way clear of large vegetation alerts contractors and others to the presence of the underground pipeline and related facilities, helping reduce the likelihood of third party damage to facilities.

 Response. A clear right-of-way will help workers and equipment respond quickly in the unlikely event of an emergency.

 Monitoring. A clear and open right-of-way allows us to frequently inspect our pipelines by patrolling them from the ground or air. These patrols help us meet our strict standards for public safety as well as requirements by the U.S. Department of Transportation, Pipeline Hazardous Materials Safety Administration.

We wanted you to know that beginning on or after { Insert Date} , we’ll be conducting right-of-way maintenance activities in your area that will involve the careful application of herbicides to targeted plant species on the right-of-way. Here’s what you can expect. In most instances, our contractors use low- volume, backpack-type sprayers to target undesirable woody plant species and tall weeds to help keep our right-of-way clear.

This process has several advantages. First, it ultimately promotes a healthy, meadow-like habitat for desirable, native plant and wildlife species. Additionally, compared to traditional methods of right-of-way maintenance such as mowing and brush-hogging, this method reduces the spread of undesirable plant species, minimizes damage to ground-nesting animals. Finally, this method also helps reduce rutting on the surface of the right-of-way, minimizes emissions and noise from mowing equipment, and reduces the frequency of right-of-way maintenance activities that could impact your property in the future.

Herbicides have been applied to control vegetation on rights-of-way in an environmentally sound manner for many years. Our contractors use only herbicides that have been approved by the Environmental

23 Protection Agency and { Insert State} for use in sensitive areas will be used, and may include: { Insert Name of Herbicides} . Our contractor will use these herbicides in accordance with all applicable federal, state, and local laws, rules, and regulations. To learn more, please refer to the attached flyer for additional information.

What do you need to do? If you’d prefer we not use herbicides on your property, please contact { Insert Contact Name} at { Insert Contact’s Telephone Number} or please send an e-mail to { Insert Contact’s e-mail Address} . If we don’t hear from you within 15 days of the date of this letter, we’ll assume you authorize { Insert Pipeline Subsidiary Contraction} to proceed with the herbicide control of vegetation on our pipeline right of way.

Finally, if you’re not the owner of this property, please help us ensure the proper owner is notified by either informing the landowner about this letter or calling the number shown above and providing the owner’s contact information so that we may do so.

{ Insert Pipeline Subsidiary Contraction} is committed to your safety and to being the Neighbor to Have in communities across our pipeline system where we operate. Working together, we can keep our pipeline safe and help protect your property.

Sincerely,

{ Insert Contact Name} { Insert Contact Title}

Enclosure: Herbicide Information Sheet

Note: For the purpose of this communication, the term “right-of-way” includes any land area for which { Insert Pipeline Subsidiary Contraction} possesses land rights, whether the rights were conveyed by a right-of-way easement, lease, or other land rights document. Also, this letter does not in any way amend or release any of { Insert Pipeline Subsidiary Contraction} ’s land rights on the property. In situations where a right-of-way agreement or other land rights document contains express authorization for herbicide use, that document will control and { Insert Pipeline Subsidiary Contraction} will proceed in accordance with the document’s provisions.

24 EXHIBIT 2 – FORM OF PRE-WORK DOOR HANGER (Pipeline Subsidiary-Specific)

25 26 APPENDICES

I. NORTHERN DIVISION – NEW JERSEY

a. Permits

b. Herbicide Labels

c. Alignment sheets