THIS IS A VIRTUAL DUPLICATE OF THE ORIGINAL HARD COPY SUBMITTED TO THE COMMISSION IN ACCORDANCE WITH ITS ELECTRONIC FILING

INSTRUCTIONS

September 7, 2012

Karen Geraghty Administrative Director Maine Public Utilities Commission State House Station 18 Augusta, ME 04333-0018 RE: CENTRAL MAINE POWER COMPANY and PUBLIC SERVICE OF NEW HAMPSHIRE: Request for Certificate of Public Convenience and Necessity for the Maine Power Reliability Program Consisting of the Construction of Approximately 350 Miles of 345 kV and 115 kV Transmission Lines (MPRP); Docket No. 2008-255 Phase II

Dear Ms Geraghty, Enclosed for filing in the above-captioned proceeding please find Central Maine Power Companys Compliance Filing pursuant to the Commissions August 10, 2012 Order on the danger tree issue. Sincerely,

Debra J. Mills Analyst, Regulatory Administration cc: All Parties

STATE OF MAINE PUBLIC UTILITIES COMMISSION

Docket No. 2008-255 (Phase II) September 7, 2012

CENTRAL MAINE POWER COMPANY and PUBLIC SERVICE OF NEW HAMPSHIRE Request for Certificate of Public Convenience and Necessity for the Maine Power Reliability Program Consisting of the Construction of Approximately 350 Miles of 345 kV and 115 kV Transmission Lines (MPRP)

COMPLIANCE FILING OF CENTRAL MAINE POWER COMPANY

Central Maine Power Company (CMP) submits this filing in compliance with the Commissions August 10, 2012 Order in this docket, which directed CMP to file within thirty (30) days the following: 1. A definition of danger trees that applies to those trees located at or outside of the Companys rights-of-way that excludes healthy trees that do not pose any immediate or obvious threat to the transmission system; and A detailed description of its current use of the wire zone border zone vegetation management practice that includes, but is not limited to a description of the Companys removal of trees in the wire zone area, the border zone area and those trees located within but close to the edge of the Companys rights-of-way.

2.

CMP provides the following information regarding these two points. I. Proposed Revised Danger / Hazard Tree Program In compliance with the August 10 Order, CMP proposes to amend its Transmission Vegetation Management Plan (TVMP) and its Field Operating Procedures (FOP) to include the language set forth below. CMP further proposes to file with the Commission the amended versions of the TVMP and FOP within ten (10) days of confirmation from the Commission that this language satisfies the August 10 Order. CMPs objective is to maintain the full width of its transmission rights-of-way (ROW), or reestablish the original cleared ROW width to ensure reliability. CMPs ROW width is determined either by ownership or easement. Side pruning is the practice of pruning or

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removing trees along the edge (sides) of a transmission ROW. CMPs procedures for side pruning are as follows. General Procedure Side pruning is accomplished by a climbing crew, mechanical tools, or an off-road bucket crew. All work methods must meet arboricultural pruning standards. Tree removal, consistent with these procedures, is the preferred method to achieve line clearance because it usually will reduce long term maintenance costs and minimize power outage risk. Branch pruning to achieve sufficient line clearance is ordinarily the last course of action. Trees that may not survive extensive pruning should be removed. Maine law, 17 M.R.S. 2511, permits public utilities to remove properly identified trees that straddle a property line to maintain adequate facilities. Stumps from removed trees shall be no taller than six (6) inches tall. Hardwood stumps are to be treated with a cut surface herbicide treatment (CST), whenever environmentally acceptable, to prevent re-sprouting. All stumps to be treated immediately after cutting. Brush and wood resulting from pruning and removals is to be left in the ROW in compliance with the Maine Slash Law. Large amounts of brush must be burned, chipped, or removed. CMP will document and track all areas containing trees that do not meet CMP FOP 400 specifications. Hazard Tree Procedures A hazard tree means any tree that is structurally unsound that could strike a conductor upon failure; examples include dead trees, unsightly trees after pruning, unhealthy trees, trees with weakened crotches, trees leaning over or towards the wires, or species known to have a high failure rate. All hazard trees within the ROW must be removed. Hazard trees, when located on the edge of the rights of ways, will be removed under the following circumstances: weak species of trees (poplar, willow, etc.), damaged trees (physical, insect, disease), dead trees, trees that have an excessive lean or other defects that would make them a threat to the safe, reliable delivery of electric power.

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Hazard trees outside of the ROW will be identified and may be removed if a high probability of failure is determined to exist. Landowner permission is required for all off ROW removals of hazard trees. The landowner will be contacted and permission secured to remove hazard trees that are outside the ROW. The Transmission Utility Arborist will be consulted regarding the removal of hazard trees outside of the ROW boundary or road limit. Danger Tree Procedures

A danger tree is defined as a tree that if it failed could contact the conductors. Danger trees within the ROW will be removed as part of ROW reclamation. Danger trees that appear healthy and are located on the edge or outside of the ROW and do not pose an obvious or immediate threat to CMP facilities under normal weather conditions will be left standing, unless the landowner consents to the removal of such trees. CMP will work with landowners to remove danger trees on the edge or outside of the ROW. The landowner will be contacted and permission secured to remove danger trees that are on the edge or outside the ROW. The Transmission Utility Arborist will be consulted regarding the removal of danger trees outside of the ROW boundary or road limit. CMP reserves the right to remove any tree that is an imminent threat to public safety. Description of its Transmission Vegetation Management Program CMP is committed to the reliable transmission of energy to all of its customers. At the

II.

same time, CMP is committed to environmental stewardship and public and employee safety. To achieve these objectives, CMPs TVMP requires a cycle of annual vegetation management that is sustainable year after year. As part of this program, CMP has incorporated a wire zone / border zone approach to managing compatible vegetation within the ROW. ANSI 300 Part 7 recognizes this approach as a best practice. Under this approach, compatible vegetation height may vary from the center of the ROW to the edge depending on conductor sag. CMPs integrated
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vegetation management program requires the selective use of herbicides to control most incompatible woody species. In areas where herbicides cannot be used or where vegetation taller than 8 to 10 feet tall exists, stems are manually removed. The wire zone is defined as the area on an electric utility ROW directly beneath and between the energized conductors to a distance (15) feet beyond the outer conductor. This area is the most likely to contain vegetation that could potentially contact the energized conductors at maximum sag. This area is also typically used as access to the poles, towers, and conductors for repair, inspection, and maintenance. CMP manages its ROWs to remove all vegetation over ten feet tall in the wire zone. This allows for good visibility of the conductors during routine inspections and allows for ingress and egress. Managing the wire zone is critical to prevent any vegetation from growing into the conductor safety zone. Compatible species for this area include, but are not limited to: perennial grass, herbaceous plants, wildflowers, sedges, rushes, Viburnum, lowbush blueberry (Vaccinium angustifolium), Forsythia, and Rhododendron. The border zone is defined as the area within the ROW outside of the wire zone, extending to the outer edge of the ROW. In the border zone, CMP controls woody species that when mature have the potential to grow into or fall into the conductors, but permits compatible species that are not capable of growing tall enough to impact the conductors. Compatible species over ten (10) feet in height may be left in the border zone. This practice allows for a softening of the edges of the ROW for aesthetics as well as wildlife habitat. Compatible species for this area include, but are not limited to: Azaleas, Speckled Alder (Alnus incana ssp. Rugosa), Honeysuckle, Canadian Yew (Taxus canadensis), most lilacs, Dwarf Burning Bush (Euonymus alatus 'Compactus') and Winterberry (Ilex verticilla).

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The compatible species lists are subject to change. Property owners planning to make plantings inside a ROW should always check with CMPs Vegetation Management Department before starting work to ensure that their particular cultivar is compatible. Respectfully submitted this 7th day of September, 2012.

____________________________________ Jared S. des Rosiers PIERCE ATWOOD LLP Merrills Wharf 254 Commercial Street Portland, ME 04101 (207) 791-1390 Counsel for Central Maine Power Company

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