Millions of acres of pipeline right-of-way crisscross all types of ecosystems. Maintaining vegetation along this land is a constant challenge and takes time and operating budget. There are many activities required by the federal government’s pipeline integrity management rules that can only be done effectively with a clear path, but by using a method called integrated vegetation management (IVM), oil and natural gas companies can help the bottom line while aiding pollinators like monarch butterflies.
The majority of rights of way are mowed or cleared on a repetitive cycle, ranging from every three to seven years. Mowing trees and shrubs, however, only controls the top of the plant and the clearing of the right of way is short-lived as the woody plants respond with vigorous re-growth to ensure their own survival. This is a constant battle that is easily lost if mowing cycle lengths grow too long.
Longer mowing cycle lengths may save money in the short term, however, clearing larger trees to reclaim a right of way can be more expensive — vegetation doesn’t stop growing.
Long used by the electric utility industry, IVM is a better method to manage vegetation to produce a well-rounded and stable plant community, and is an approach NiSource and its Columbia Gas and NIPSCO subsidiaries are using to create new pollinator habitats along rights-of-way.
Value of IVM to Pipeline Industry
IVM can be employed on both interstate pipelines and distribution systems to manage vegetation in a way that will facilitate inspections, testing and general maintenance without first having to clear the vegetation. Consensus industry standards describe it as “a system of managing plant communities in which managers set objectives, identify compatible and incompatible vegetation, consider action thresholds, and evaluate, select and implement the most appropriate control method or methods to achieve their established objectives.”
This definition contains two critical elements that lead to effective implementation of IVM: First, delineating what vegetation is compatible and incompatible, and second, developing a systematic approach for building compatible plant communities by discouraging incompatibles. The control methods used in IVM include mechanical, chemical, biological and cultural.
Mechanical controls such as mowing or chainsaw clearing are usually where a program begins before progressing to the use of herbicides to control woody plants. Herbicides prevent the regrowth of cut woody plants and allow compatible herbaceous plants to become established on the right of way.
As IVM programs mature, it encourages the establishment of a native low-growing, stable grassy and broadleaf plant community known as an early successional habitat. These plants create biological controls that help resist the re-establishment of woody plants and can reduce the use of herbicides.
Low-growing native plant communities can provide safe, economical and accessible rights of way. Managing a right of way with IVM has environmental benefits in addition to meeting operational needs. Focusing on promoting these plants instead of constantly removing thick, woody plants reduces the need for routine cutting, which lowers the company’s carbon footprint and the burning of fossil fuels by mowers and other equipment.
Soil disturbance, erosion and stream sedimentation are also minimized. With IVM, right-of way corridors can be managed to restore native prairie, meadow and shrub habitats that are attractive to the community and provide food and shelter for a wide variety of birds, insects and other wildlife.
Propping Up Pollinators
Pollinators are one of the most important groups of species that benefit from the habitats produced by IVM. Pollinators including bees, hummingbirds and especially monarch butterflies are in decline, and the U.S. Fish & Wildlife Service cites habitat loss as a major contributing factor.
Pollinators are responsible for moving pollen from one plant to another, spurring plant fertilization and successful seed and fruit production. They are a vital part of the ecosystem that help produce one out of every three bites of food. According to the Pollinator Partnership, the largest group in the world dedicated to protecting these insects and small animals, there are about 1,000 plants used in food, beverages, fibers, spices and medicines that need pollination to produce the goods on which we depend.
NiSource and other utility and pipeline companies are increasingly recognizing the value of supporting pollinator conservation. Managing rights of way for habitat contributes to a company’s sustainability and biodiversity metrics and provide a positive outcome for nearby communities.
NiSource has several projects across its seven-state territory where pollinator habitats are being proactively established. These take place during restoration activities on major infrastructure projects, through IVM or by partnering with landowners who also see the value in helping pollinators. In the Lexington, Kentucky, area, we recently started a pilot program to remove existing vegetation and sow a specialized seed mixture that will grow plants like milkweed, gray goldenrod, prairie cone flower and white prairie clover to attract pollinators and require less mowing and maintenance.
Doing the right thing sometimes comes with its own set of challenges. For example, one challenge comes with the creation of habitat suitable for endangered species or species likely to be listed as endangered. The monarch butterfly, one of the most recognizable pollinator species, uses early successional habitats that are established by IVM practices.
The butterfly leaves its Mexican winter home in March and migrates all the way to Canada and the northern U.S. states, breeding multiple generations along the way. They are facing challenges that may result in an endangered species listing in 2019. But NiSource and other companies have joined with the University of Illinois at Chicago in a voluntary conservation program to proactively enhance habitats while allowing necessary infrastructure maintenance activities.
A voluntary conservation program can help prevent the monarch butterfly from being listed on endangered species lists — and avoid the problems found in Indiana regarding bats.
Creating or promoting certain habitats on rights of way for species that are endangered or likely to become endangered could seem like a risky plan. The reality is that any right of way, intentionally managed for pollinator habitat or not, can potentially be monarch habitat. Should the monarch butterfly be listed as an endangered species, any work taking place on the right of way, whether on the pipeline facility itself or the vegetation, may impact the species.
Those familiar with the clearing restrictions related to the endangered Indiana bat understand the challenges all too well. With much of the pipeline right-of-way in the butterfly’s range, listing the monarch as threatened or endangered could impact operators and how they maintain their right of way especially in areas specifically designed to create new habitat.
The U.S. Fish & Wildlife Service runs a voluntary program called the Candidate Conservation Agreement with Assurances, or CCAA. This is a tool that provides regulatory assurances to property owners, including easement holders, who voluntarily agree to manage lands so that threats to the potential endangered species are removed or reduced.
A company that signs a CCAA with the Service is issued an enhancement-of-survival permit that provides the property owner with the assurance that they will not become responsible for additional conservation measures and will not incur additional future regulatory obligations if the covered species is listed under the Endangered Species Act. The property owner is only responsible for implementing and maintaining the conservation measures that they agree to in the CCAA.
When evaluating the CCAA the U.S. Fish & Wildlife Service must determine that the benefits of the conservation measures to be implemented by a property owner under a CCAA, when combined with those benefits that would be achieved if the conservation measures were also to be implemented on other necessary properties, would preclude or remove the need to list the covered species.
Applicants must only address those threats or the portion of the threats that they can control on the property enrolled in the CCAA. These threats are defined as covered activities and should include any operations and maintenance items that must take place on the right of way. To address the threats property owners can protect, manage and/or enhance existing populations or habitats on the enrolled property. IVM is one of the primary conservation measures that can be employed on rights-of-way to meet the requirements of the CCAA.
The listing decision for whether the monarch butterfly is listed is coming in June 2019 and covers a range that includes most of the United States. Like-minded organizations whose facilities are located on rights-of-way have pooled their resources to begin development of a CCAA. This type of agreement will allow individual applicants to work under a central plan.
With guidance from the U.S. Fish & Wildlife Service, the Right-of-Way as Habitat Working Group led by the University of Illinois at Chicago’s Energy Resources Center is working with right of way managers from many industries on the development of a draft CCAA. This opportunity is available to utilities, oil and gas pipelines, railroads, Departments of Transportation and any other industry with right-of-way interests. The group is currently on track to have the draft completed and approved prior to the listing decision next year.
Proponents of the monarch butterfly are encouraging an all-hands-on- deck approach to help support recovery efforts. By getting coverage under a CCAA and using IVM as the primary conservation measure to create and enhance monarch butterfly habitats, companies will be able to meet the ecological goals along with the integrity management requirements that drive the company in its efforts to deliver their product safely and efficiently.
Kelly Carmichael is vice president of environmental at NiSource, where he leads environmental policy, permitting and compliance, as well as sustainability functions.