INTEGRATED VEGETATION MANAGEMENT PLAN FOR KINDER MORGAN CANADA FACILITIES

INTEGRATED VEGETATION MANAGEMENT PLAN FOR KINDER MORGAN CANADA FACILITIES January 18 th, 2016

Executive Summary This Integrated Vegetation Management Plan (IVMP) applies to all Kinder Morgan Canada (KMC) facilities within the geographic boundaries of the plan area. Facilities are all fenced compounds that have physically restricted access. Facilities include pump stations, terminals, valve stations and mainline valves, tank farms, and maintenance locations, office buildings/complexes, electrical sub-stations and undeveloped areas (for future expansion) within the facilities. The management of problem vegetation, noxious weeds and invasive plants for pipeline rights-of-way and associated access roads to the rights of ways and facilities are outlined in the Integrated Vegetation Management Plan, which is a separate plan. This IVMP has been prepared to address KMC s long term weed monitoring, control procedures, decision making criteria as well as accountability and responsibility for facilities along KMC s pipeline system(s). This plan has been prepared to comply with all acts, regulations and guidelines in the applicable jurisdictions traversed by the KMC Trans Mountain and Jet Fuel pipeline systems. The plan will be a part of KMC s overall plan for vegetation management in British Columbia, and applies to all KMC facilities within the geographic boundaries of the plan area. The Trans Mountain pipeline system extends from Edmonton, Alberta to Burnaby, BC and was constructed in 1952/1953. This system includes numerous above-ground facilities including; terminals, pump stations, tank farms, main line valves and maintenance facilities. KMC is responsible for the safe and efficient movement of crude oil and refined products within their pipeline systems. Problem vegetation growing within KMC facilities must be controlled for reasons of safety and fire control, as well as to ensure facility site security. Vegetation includes herbaceous grasses, broadleaf species, woody tree and shrub species (i.e. problem vegetation), noxious weeds and invasive plants. The IVMP is intended use is for KMC managers, auditors, regulators, field personnel and any other users of the plan. The plan includes various levels of detail about weed monitoring and control relevant to the users of the plan. The plan is also developed based off of KMC s Environmental standards, procedures and policies. KMC is committed to conducting its business in as safe and environmentally responsible manner. KMC will utilize the principles of integrated pest management (IPM) to manage problem vegetation and noxious weeds and invasive plants. The vegetation management practices described in this IVMP will include both non-chemical and chemical (herbicide) options, and will discuss the selection process that KMC will use to decide on the most appropriate method(s) of vegetation management. This IVMP is the legal authority for KMC to utilize pesticides for the purposes indicated above. All vegetation management activities will be undertaken in a manner that complies with this IVMP, which has been developed in accordance with section 58 of the Integrated Pest Management Regulation (BC Reg. 604/2004).

1.0 INTRODUCTION... 1 1.1 Kinder Morgan Canada (KMC) Background... 1 1.2 Federal and Provincial Legislative Requirements for Controlling Problem Vegetation, Noxious Weeds and Invasive Plants... 2 1.3 Objectives of Facilities Integrated Vegetation Management (IVM)... 3 1.4 The Elements of the KMC IVM Program... 3 1.5 Identifying Information... 5 1.5.1 Person Responsible for Managing Pests (Vegetation)... 5 1.5.2 Geographic Boundaries of the Area to Which This Plan Applies... 5 1.6 Role and Term of This Plan... 5 1.7 The KMC Health, Safety and Environment Policy and Procedures... 5 2.0 The KMC IVMP PLAN FOR PROBLEM VEGETATION MANAGEMENT AT FACILITIES... 6 2.1 Introduction... 6 2.2 What Facilities Include... 7 2.3 Reasons for Control of Problem Vegetation at Facilities... 7 2.4 Objectives of Vegetation Management at Facilities... 7 2.5 Prevention... 9 2.5.1 Surfacing Materials... 9 2.5.2 Maintaining Perimeter Fences Free of Problem Vegetation...10 2.5.3 Seeding Disturbed Areas...10 2.6 Identification of Species...10 2.6.1 Types of Problem Vegetation at Facilities...11 2.6 Monitoring Program for Problem Vegetation at Facilities...12 2.6.1 Monitoring Methods...13 2.6.2 Frequency of Monitoring...13 2.6.3 Data Collected During Pre-Treatment Site Monitoring...14 2.7 Treatment (Injury) Thresholds...14 2.7.1 How Treatment (Injury) Thresholds are Chosen...15 2.7.2 How Treatment (Injury) Thresholds are Applied...16 2.7.3 Specific Injury (Treatment) Thresholds...16 2.8 Vegetation Management Options...18 2.8.1 Manual and Mechanical (Non-Chemical) Control Options at KMC Facilities...20 2.8.2 Cultural (Non-Chemical) Control Options at KMC Facilities...23 2.8.3 Chemical Control Options (Herbicides) at KMC Facilities...24 2.9 Treatment Selection Criteria...24 2.10 Post-Treatment Monitoring/Evaluations...25

3.0 The KMC IVMP FOR NOXIOUS WEED AND INVASIVE PLANT MANAGEMENT PROGRAM FOR FACILIITES...26 3.1 Noxious Weeds...26 3.2 Invasive Plants...27 3.3 The KMC Noxious Weed and Invasive Plant Management Program...28 3.4 Prevention...29 3.5 Pest Identification...30 3.6 Monitoring and Establishing Injury (Treatment) Thresholds...30 3.6.1 Monitoring Populations...30 3.6.2 Establishing Injury (Treatment) Thresholds...31 3.7 Treatment Options for Noxious Weeds and Invasive Plants at Facilities...33 3.7.1 Manual and Mechanical Control Methods...34 3.7.2 Cultural Control Methods...35 3.7.3 Chemical Control (Herbicides)...36 3.8 Treatment Selection Criteria...36 3.9 Evaluation of Herbicide Treatments (Post-Treatment Monitoring)...37 4.0 OPERATIONAL INFORMATION...38 4.1 Qualifications and Responsibilities of Persons Applying Herbicides...38 4.2 Procedures for Safely Transporting Herbicides...39 4.3 Procedures for Safely Storing Herbicides...39 4.4 Procedures for Safely Mixing, Loading and Applying Herbicides...39 4.5 Procedures for the Safe Disposal of Empty Herbicide Containers and Unused Herbicides...40 4.6 Procedures for Responding to Herbicide Spills...40 4.7 Herbicide Identification, Use Areas, Properties and Use Patterns for All Herbicides Proposed for Use...41 4.7.1 Herbicide Identification and Use Areas...41 4.7.2 Properties of Herbicide Active Ingredients...42 4.7.3 Use Patterns of Herbicide Active Ingredients...43 4.7.4 Use of Surfactants or Adjuvants...47 4.8 Herbicide Application Equipment, Methods and Techniques...47 4.8.1 Herbicide Application Equipment...48 4.8.2 Herbicide Application Methods/Techniques...48 5.0 ENVIRONMENTAL PROTECTION STRATEGIES AND PROCEDURES...50 5.1 Strategies to Protect Community Watersheds...50 5.2 Strategies to Protect Domestic and Agricultural Water Sources and Bodies of Water...50 5.3 Strategies for Protecting Fish and Wildlife, Riparian Areas and Wildlife Habitat...53

5.3.1 Strategies to Protect Riparian Areas...53 5.3.2 Strategies to Protect Wildlife and Habitat...55 5.4 Strategies to Prevent Herbicide Contamination of Food Intended for Human Consumption...56 5.5 Pre-Treatment Inspection Procedures for Identifying Treatment Area Boundaries...56 5.6 Procedures for Maintaining and Calibrating Herbicide Application Equipment...57 5.7 Procedures for Monitoring Weather Conditions and Strategies for Modifying Herbicide Application Methods for Different Weather Conditions...57 5.7.1 Weather Monitoring...57 5.7.2 Stop Treatment Conditions...57 6.0 REPORTING, NOTIFICATION AND CONSULTATION...57 6.1 Reporting...57 6.1.1 Confirmation Holder Use Records...58 6.1.2 Annual Report for Confirmation Holders...58 6.2 Notifications...58 6.2.1 Notification of IVMP Confirmation...58 6.2.2 Annual Notice of Intent to Treat...58 6.2.3 Requests to Amend the IVMP...59 6.2.4 Notification of Contraventions...59 6.2.5 Public Notification Prior to Treatment...59 6.2.6 Posting of Treatment Notices...59 6.3 Consultations...60 6.3.1 Public Consultation Plan...60 6.3.2 Public Consultation Report...61 6.3.3 First Nations Consultations...61 List of Tables Table 1: Federal and Provincial Legislation Governing Control of Problem Vegetation, Noxious Weeds and Invasive Plants in Facilities... 2 Table 2: Web Sites for Identification of Tree, Shrub, and Problem Vegetation Species...11 Table 3: Treatment (Injury) Thresholds for Specific Sites Within a Facility...17 Table 5: Description of, Rationale and Selection Criteria for, and Benefits and Limitations of Manual and Mechanical (Non-Chemical) Control Methods for Vegetation Management at KMC Facilities...20 Table 6: Description of, Rationale and Selection Criteria for, and Benefits and Limitations of Cultural Control Methods for Vegetation Management at KMC Facilities...23

Table 7: Current Provincial and Regional Weeds Designated by Regulation as Noxious Under the BC Weed Control Act and Regulations (2015)....26 Table 8: Plants Currently Listed as Invasive Under the Forest and Range Practices Act, Invasive Plant Regulation...28 Table 9: Web Sites for Identification of Noxious Weed and Invasive Plant Species...30 Table 10: Categories of Invasive Plant Species of Current Priority at KMC Facilities Based on Visual Observations During Monitoring...31 Table 11: Noxious Weed and Invasive Plant Site Risk Levels...32 Table 12: Injury (Treatment) Thresholds for the Noxious Weed and Invasive Plant Program 32 Table 13: Vegetation Management Options, Methods and Techniques for Control of Noxious Weeds and Invasive Plants at Facilities...33 Table 14: Description of, Rationale and Selection Criteria for, and the Benefits and Limitations of Manual and Mechanical (Non-Chemical) Control Methods...34 Table 15: Description of, Rationale and Selection Criteria for, and the Benefits and Limitations of Cultural Control Methods...35 Table 16: Identification of Herbicide Active Ingredients Proposed for Use in Facilities and Their Use Areas...41 Table 17: Properties of Herbicide Active Ingredients Proposed for Us...42 Table 18: Use Patterns of Herbicide Active Ingredients Proposed for Use...43 Table 19: Description of, Rationale and Selection Criteria for, and Benefits and Limitations of Chemical (Herbicide) Control Methods/Techniques....48 Table 20: Minimum Water Protection Measures for Herbicide Applications...52 List of Appendices Appendix 1: List of KMC Facility Names, Locations and Facility Types...63 Appendix 2: Maps of the KMC Pipeline Systems in British Columbia Showing Locations of Facilities...65 Appendix 3: KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants...71 Appendix 4: KMC Post-Treatment(s) Monitoring Form...76 Appendix 5: Weeds of Management Concern for the Trans Mountain and Express Pipeline Systems...78

1.0 INTRODUCTION The British Columbia Integrated Pest Management Act includes provisions to require pesticide use be conducted under a single, comprehensive Integrated Vegetation Management Plan (IVMP). An IVMP is required for pesticide use on public and some types of private land. On private land used for forestry, transportation or public utility purposes, or otherwise for the commercial transmission of electricity, natural gas, oil or water to or for the public or a corporation, a confirmed IVMP is required for the use of pesticides. An IVMP means a plan that describes: A program for managing pest populations or reducing damage caused by pests based on integrated pest management (IPM); and, The methods of handling, preparing, mixing, applying and otherwise using pesticides within an integrated vegetation management (IVM) program. This document is an Integrated Vegetation Management Plan (IVMP) for the management of problem vegetation, including noxious weeds and invasive plants, within all facilities owned and/or controlled by Kinder Morgan Canada (KMC) in British Columbia. This IVMP for facilities vegetation management is designed to replace the existing IVMP (Confirmation # 827-0002-2011/2016) that expires on July 19, 2016. This plan has been prepared in accordance with Section 58 of the BC Integrated Pest Management Regulation (IVMR) (BC Reg. 604/2004). 1.1 Kinder Morgan Canada (KMC) Background KMC operates Trans Mountain Pipeline LP (TMPL), the only pipeline system that transports crude oil and refined products from Edmonton, Alberta (via Kamloops and Sumas) to the Burnaby Terminal (the terminus of the Trans Mountain pipeline) for temporary storage and distribution, as well as the Trans Mountain (Jet Fuel) Inc. pipeline system that transports aviation turbine fuel. TMPL has been in operation since 1953. Through separate pipelines, products are distributed to local terminals and refineries and to the Westridge Marine Terminal. Some refined products are also distributed locally from Kamloops. In Sumas, crude oil and refined products are transported via pipeline to refineries in the Puget Sound area of Washington State via the Trans Mountain (Puget Sound) LLC pipeline. At the Westridge Marine Terminal in the Port of Vancouver, crude oil from the pipeline is shipped to the west coast of the United States or overseas, and aviation turbine fuel is imported and stored for delivery to Vancouver International Airport for storage and distribution. This IVMP relates only to the management of problem vegetation, including noxious weeds and invasive plants, within the facilities described in section 1.1, listed in Appendix 1, and shown on the maps in Appendix 2. The management of problem vegetation, including noxious weeds and invasive plants, within all pipeline rights-of way (including access roads to rights-of-way and to KMC facilities) owned and/or controlled by Kinder Morgan Canada (KMC) for oil transmission and distribution within British Columbia are not included in this IVMP. 1

1.2 Federal and Provincial Legislative Requirements for Controlling Problem Vegetation, Noxious Weeds and Invasive Plants There are certain legislative requirements that must be met/followed by KMC for controlling problem vegetation, noxious weeds and invasive plants within KMC facilities in British Columbia. A summary of the applicable federal and provincial legislation is shown in Table 1, and is described in detail in sections 1.3, 2.7.3, 3.1, and 3.2. Local governments may have their own legislation that is applicable to controlling problem vegetation, noxious weeds and invasive plants. KMC and its contractors must be aware of potential Bylaws that are applicable to the jurisdiction in which works are occurring. Table 1: Federal and Provincial Legislation Governing Control of Problem Vegetation, Noxious Weeds and Invasive Plants in Facilities Ministry/Agency Legislation Regulations Canada National Energy Board National Energy Board Act Onshore Pipeline Regulations Canada National Energy Board BC Oil and Gas Utilities Act Oil and Gas Utilities Regulation (Jet Fuel Pipeline) Environment Canada Fisheries Act Environment Canada Migratory Bird Convention Act Environment Canada Transport Canada Species at Risk Act Transportation of Dangerous Goods Act Transportation of Dangerous Goods Regulations Health Canada Canada Health Act Health Canada Pest Management Regulatory Pest Control Products Act Pest Control Products Regulations Agency Health Canada Pest Management Regulatory Agency Pest Control Products Act Pest Control Products Incident Reporting Regulations BC Ministry of Agriculture BC Weed Control Act Weed Control Regulations BC Ministry of Environment (Environmental Protection Division) BC Integrated Pest Management Act Integrated Pest Management Regulation BC Ministry of Environment BC Ministry of Environment BC Ministry of Environment BC Ministry of Forests, Lands and Natural Resource Operations BC Environmental Management Act BC Environmental Management Act BC Wildlife Act BC Forest and Range Practices Act Spill Reporting Regulations Hazardous Waste Regulation Invasive Plants Regulation 2

BC Ministry of Forests, Lands and Natural Resource Operations BC Ministry of Health BC Wildfire Act BC Drinking Water Protection Act Wildfire Regulation Drinking Water Protection Regulation 1.3 Objectives of Facilities Integrated Vegetation Management (IVM) Problem vegetation includes all plant life. Depending on the type of facility, legislated responsibilities and safety concerns may dictate the need for vegetation management. In this context, vegetation may include grasses, sedges, forbs, vines, ferns, brush and trees (deciduous and conifers), as well as noxious weeds and invasive plants (which are either annuals, biennials or perennials). The specific objectives of the KMC facilities IVM program are: To manage vegetation as per applicable federal and provincial legislation (including noxious weeds and invasive plants as regulated by the BC Weed Control Act (BCWCA) within pump stations, terminals, valve stations and mainline valves, tank farms, and maintenance locations, office buildings/complexes, electrical sub-stations and undeveloped areas (for future expansion) within the facilities. To comply with provisions of the BC Wildfire Regulation (BCWR) with respect to maintaining facilities located within 300 meters of forested land or grassland areas in a manner that prevents any fire from spreading; To minimize worker and public safety hazards at all facilities; To reduce the incidents of accidents, fires and system failures caused by the presence of vegetation; To comply with all KMC vegetation management policies; and To ensure that vegetation management activities are undertaken in a manner that minimizes the risk to the environment and human health; and, To comply with the KMC Health, Safety and Environmental Policies and Environmental Standards, Procedures and applicable Guidelines. 1.4 The Elements of the KMC IVM Program KMC is committed to ensuring that the IVMP for KMC s facilities IVM program is implemented effectively, is well documented, and is reviewed and updated on a regular basis. Review and revisions take place every five years (minimum) to ensure that the most effective vegetation management monitoring and weed control practices are continually used to achieve the objectives of the IVM program. The elements of IVM that will be used to manage vegetation at KMC facilities are: Prevention - Preventative measures aimed at stopping the introduction, initial growth and spread of weeds is an important component of the IVMP. These measures have been, and will be, incorporated into new facility construction and site maintenance activities. 3

Management of ecosystems surrounding the facilities will help to prevent undesirable vegetation from becoming a problem; Identifying - Vegetation specialists will accurately record problem vegetation, noxious weed and invasive plant locations and extent at KMC facilities during routine inspections and monitoring activities. KMC defines a vegetation specialist as a person who has demonstrated knowledge and experience with identifying weeds. The vegetation specialists can range from KMC field personnel or EHS Coordinators to third party consultants who have training in proper weed identification. Weed specialists will be familiar with noxious and invasive species on a federal, provincial level, and within municipal and regional district jurisdictions within BC where the target area for treatment/monitoring is located; Monitoring - Consists of regular inspections to determine the extent of problem vegetation, noxious weeds and invasive plants, and provides information needed to decide whether treatments are necessary (treatment thresholds), based on best timing of treatments and best treatment options. Inspection frequency should address the level of risk imposed by activities within the facilities. Monitoring includes documentation of desirable vegetation and beneficial organisms; Treatment Threshold - Categories are adopted from plant committees and agencies and are used to establish injury (treatment) thresholds, treatment methods and priorities. The location, density, growth stage, plant category (degree of invasiveness) and site risk levels of the problem vegetation and noxious/invasive species are recorded during monitoring events. The noxious/invasive weeds are put into categories that are used to establish treatment thresholds and treatment methods (priorities). Third party consulting or in house personnel are utilized to provide recommendations for site conditions observed and if treatment is required; Treatment Options - When treatment thresholds are surpassed, an approved course of action is implemented. The IVMP takes into account options that are available for an array of vegetation complexes. The decision making process ensures that the most suitable, effective, environmentally compatible and cost effective option or combination of options is selected for weed management at a particular facility. Depending on the type of vegetation to be controlled various treatment options are available (biological, physical, cultural, mechanical, behavioural and chemical). A combination of nonchemical and chemical treatment options is generally most effective when tailored to weed species and conditions at each facility; and, Evaluating - Treatment evaluations are mandatory for all treatment areas following herbicide application. Daily operating records and spray maps completed by the herbicide applicator will be retained after any treatment at KMC facilities. The daily operating records information will be included in the Annual Summary of Pesticide Use that is submitted to the Ministry of Environment regional office for each calendar year. KMC personnel or third party consultants will be completing KMC s in house pre and post treatment inspection forms which evaluates in detail the effectiveness of vegetation management activities. Records of inspections and weed control activities will be maintained in KMC s management system folders. Each of above IVM elements forms an integral part of the KMC IVM program at facilities, and will be discussed in separate sections as follows: 4

2.0 The KMC IVM Program for Problem Vegetation Management at Facilities; and, 3.0 The KMC Integrated Noxious Weed and Invasive Plant Management Program at Facilities. 1.5 Identifying Information 1.5.1 Person Responsible for Managing Pests (Vegetation) [IPMR Section 58(1)(b)(c)] The person responsible for managing vegetation on land owned or controlled by KMC, and the principal contact for information relating to this IVMP, is Mike Droppo, P.Ag., Manager of Environment Department, KMC. Mr. Droppo can be contacted at (403) 514-6537 or Mike_Droppo@kindermorgan.com 1.5.2 Geographic Boundaries of the Area to Which This Plan Applies [IPMR Section 58(1)(a)] This plan applies to all 25 KMC facilities within British Columbia. The name, location and type of the 25 KMC facilities are listed in Appendix 1. Maps showing the locations of all 25 KMC facilities within British Columbia to which this plan applies are shown in Appendix 2. During the term of this IVMP, additional facilities may be established, as required for operational purposes, within the geographic boundaries of this IVMP. 1.6 Role and Term of This Plan [IPMR Section 59(1)(j)] This plan permits KMC to utilize herbicides, in certain situations, at all KMC facilities within British Columbia and the geographic boundaries of the IVMP area. This plan shall be in force for a five-year period from the date that Confirmation of a Pesticide Use Notice has been obtained from the BC Ministry of Environment. 1.7 The KMC Health, Safety and Environment Policy and Procedures KMC is committed to the concept of sustainable development and recognizes its responsibilities in the field of environmental management. KMC s Environmental Policy is one of high corporate priority. KMC strives to contribute to the protection of the environment by integrating environmental priorities into their IVM program, and by continuously improving its environmental performance. KMC is committed to conducting its IVM program in a safe and environmentally responsible manner. In addition to the Environmental Policy, KMC has developed several environmental procedures and guidelines including, but not limited to, the following: 5

Identifying Project Environmental Requirements; Terrestrial Wildlife Habitat and Protection; Working In-and-About a Watercourse; Soil Management; Re-vegetation; Post Disturbance Monitoring; and, Vegetation and Pest Management; In order to meet the above commitment, KMC and its employees will: Comply with all applicable laws, company policies and industry codes of practice and require the same of their contractors; Identify and manage risks to prevent or reduce possible adverse consequences from their operations; Be prepared for emergencies and coordinate their response plans with emergency response organizations in the communities where they operate; Train employees to be aware of and meet their responsibility for protection of health, safety and the environment; Integrate health, safety and environmental protection measures into all elements of their business; Communicate openly with stakeholders about their activities and their impact on health, safety and the environment and respond promptly to their concerns; Work with industry associations, governments and other stakeholders to establish standards for health, safety and the environment appropriate to their business; Use resources efficiently and effectively; and, Regularly monitor their health, safety and environmental performance and strive for continuous improvement. 2.0 THE KMC IVMP FOR PROBLEM VEGETATION MANAGEMENT AT FACILITIES 2.1 Introduction This section deals specifically with the objectives and steps for managing problem vegetation at KMC facilities using the principles of IVM. Section 3.0 of this document will describe the objectives and steps for managing noxious weeds and invasive plants at KMC Facilities. Access to KMC facilities is required or maintenance, safety inspections, repairs, leak and pressure testing and spill response. Access is also important for worker and public safety as well as functions as a mechanism to reduce the potential for fires. All of the above dictate the need for vegetation management. Vegetation includes all plant life and the decision to initiate vegetation management will be influenced by the type of vegetation growing in the facility. Generally, such factors as current height, growth rate/potential, and degree of invasiveness are considered. Management may be initiated if vegetation interferes with identification and sight line (i.e., visibility) requirements or restricts access for maintenance, repairs, leak and pressure testing, or spill response. 6

Vegetation management programs at KMC facilities target problem vegetation, noxious weeds and invasive plants. Problem vegetation includes herbaceous grass and broadleaf weeds, woody tree and shrub species. Problem vegetation is a primary concern when it is growing adjacent to piping, buildings, parking areas, and perimeter fences. The process of developing an effective IVM program for KMC facilities includes: Gathering information on the types of vegetation growing at each site (i.e., an inventory); Deciding when (i.e., establishing an injury threshold), how often, and by which method the control should be carried out; Developing short and long term plans; Preparing cost estimates and budgets; Directing and controlling the control work (i.e., contract monitoring); and, Evaluating the process to ensure that necessary modifications are implemented when required. 2.2 What Facilities Include Within this IVMP, facilities include: Pump stations; Maintenance locations; Terminals; Valve stations and mainline valves; Tank farms; Office buildings/complexes and electrical sub-stations within facilities; and, Undeveloped areas within facilities (for future expansion). 2.3 Reasons for Control of Problem Vegetation at Facilities There are numerous reasons why problem vegetation must be managed within KMC facilities and around their perimeter fences. Some of these reasons are: Problem vegetation can become a fire hazard or serve as a fuel source for fires; Problem vegetation can restrict access to equipment for maintenance, repairs, safety inspections and emergency response; Problem vegetation growing outside perimeter fences can serve as a seed source; Problem vegetation can increase the risk of slipping and tripping; and, Problem vegetation can serve as shelter and food for structural insect pests, especially rodents. 2.4 Objectives of Vegetation Management at Facilities The overall goal of the IVMP is to eliminate infestations of problem vegetation, noxious weeds or invasive plants established in facilities and around their perimeter fences. This will reduce the 7

potential of problem vegetation, noxious weeds and invasive plants becoming established along the pipeline systems owned and/or operated by KMC. KMC has developed short-term and longterm objectives for the management of problem vegetation, noxious weeds and invasive plants within facilities. The objectives and steps for managing noxious weeds and invasive plants at facilities will be described in detail in section 3.0. Short Term Objectives Short-term objectives will be completed in a 1-3 year timeframe and include the following: Stopping the spread of noxious and invasive plants that may spread and threaten un-infested, highly susceptible sites, including adjacent agricultural lands (cultivated fields, hay and pasture land) as well as adjacent lands determined to be of high economic or aesthetic value (areas near parks, residential areas and cemeteries etc.); Reducing the aerial extent of infestations within and around the perimeter of facilities. Controlling vegetation below established injury (threshold) levels required for the safe and efficient operation of pipeline equipment; Minimizing worker and public safety hazards; Maintaining system operation and reliability by reducing the incidence of accident or system failure; Using the most effective and efficient vegetation management techniques; Minimizing the need for vegetation management treatments through the use of IVM principles; Ensuring all vegetation management activities are conducted in a manner that minimizes the risk to the environment and human health, and minimizes or eliminates off-site impacts. Ensuring compliance with all pertinent government regulations, KMC policies and environmental standards and guidelines; Complying with provisions of the Species at Risk Act and the BC Wildlife Act; Working with local land authorities to ensure compliance and cooperation of weed control efforts. Land authorities may include, but are not limited to: private landowners, municipal/regional districts, provincial parks representatives, federal and provincial regulators. Long Term Objectives Long-term objectives include the following: Reducing or preventing spread of problem vegetation, noxious weeds and invasive plants within KMC facilities and around their perimeter fences; Reducing existing infestations of problem vegetation, noxious weeds and invasive plants to a level equivalent to the level observed in adjacent lands with equivalent or similar land use by judging whether an infestation has been significantly changed/or reduced. Improved documentation and tracking of surrounding land use infestations; Considering preventative, non-chemical vegetation management when designing, planning and constructing new facilities, or when conducting operations and maintenance activities; Actively using and evaluating new vegetation management techniques and practices to improve vegetation management programs by designing and managing more effective herbicide applications, testing alternatives to herbicides, and using them where appropriate; Continually reviewing herbicide products, and updating herbicides used based on new products available and application methods that have the lowest environmental impact; and 8

2.5 Prevention [IPMR Section 58(2)(a)] In order to meet their vegetation management objectives, KMC employs preventative measures aimed at stopping the initial growth and spread of problem vegetation as an important component of the IVM program at KMC facilities. These measures are incorporated, where feasible and practical, into facility designs prior to construction, or may be implemented during regular operational and maintenance activities or facility upgrades. Some of the preventative measures that KMC may employ include: Use of appropriate surfacing materials within facilities; Maintaining perimeter fences free of vegetation; and, Seeding disturbed areas. 2.5.1 Surfacing Materials The proper selection and installation of surfacing materials is important in minimizing growth of problem vegetation within KMC facilities. The presence of organic material, such as soil fines, provides a growth medium for problem vegetation. Suitable surfacing material of a correct thickness and free of organic material can reduce the establishment of problem vegetation. The options for surfacing materials that will be considered by KMC during the construction of new facilities, and upgrading of existing facilities, include the use of crushed rock/gravel (washed where available), landscape fabric (geotextile), and asphalt and concrete. Clean Crushed Rock/Gravel The most effective way to prevent problem vegetation from establishing within facilities is by maintaining a 15 cm layer of clean, crushed rock or gravel in and around areas that have zero tolerance for problem vegetation. Clean, crushed rock or gravel is also the predominant surfacing material used within, and for 2 meters around each sub-station that is located within or adjacent to a KMC facility, and within the 2 m strip around perimeter fences. The use of clean, crushed rock or gravel will help to reduce the germination and establishment of weed seeds from adjacent areas by eliminating a source of organic matter needed for their establishment. At facilities that have an electrical sub-station, it will also help reduce electrical exposure to workers and the public, as the grounding system (grid wires) extends below the crushed gravel outside the perimeter fence. The main advantages of using clean, crushed rock or gravel as a surfacing material include: It promotes rapid drainage of water from the site; Within electrical sub-stations, it maintains the moisture content of the underlying soil, thus increasing the soil's ability to conduct electrical current away from the surface and into the ground; It is economical and is widely available; It greatly impedes the establishment of problem vegetation; It is non-flammable, and helps to prevent fires in areas around oil-filled equipment; It provides a suitable surface for the movement of equipment and vehicles; and, It helps control dust. 9

Crushed Rock over Geotextile KMC may use geotextile to exclude weeds from landscaped areas within or adjacent to facilities. Geotextile is a porous polypropylene fabric that is placed below mulches in landscaped areas such as flower or shrub beds. It works by preventing root growth of the unwanted vegetation. The effectiveness of clean, crushed rock or gravel for excluding problem vegetation can be enhanced with a geotextile layer close to perimeter fences, and in areas where herbicides cannot be used. Geotextile can also be staked to the soil in areas without crushed rock or gravel. Asphalt and Concrete The use of asphalt and concrete may be considered for use around buildings and piping, and in parking areas to serve as a barrier to problem vegetation becoming established. 2.5.2 Maintaining Perimeter Fences Free of Problem Vegetation Problem vegetation growing adjacent to perimeter fences will generally be removed or controlled because: Large trees (especially deciduous) and shrubs can deposit organic debris into the facilities, compromise facility security by improving access over the fence, and can create safety and fire hazards if they grow too close to equipment; They can also restrict visibility and inhibit site access if not removed from access roads, and could be spread by vehicles and personnel to non-infested areas; Certain types of problem vegetation can grow through/entwine chain link fencing, thus providing a seed source for new growth on gravel areas within the facility, and can also compromise site security and act as a fuel source for fires; Overgrown problem vegetation can impact site aesthetics, especially in landscaped or urban areas; and, Noxious weeds and invasive plants growing anywhere within the facility, including around perimeter fences, may have to be removed to comply with provisions of the BCWCA and BCWCR and the FRPA, Invasive Plant Regulation. Control of noxious weeds and invasive plants will be further discussed in section 3 of this IVMP; and, Generally, vegetation growing within the 1 or 2 meter strip around perimeter fences will be managed. 2.5.3 Seeding Disturbed Areas Soils disturbed during construction of new facilities, upgrading of facilities or other activities will be seeded and fertilized if other surfacing materials are not being installed. These areas can also provide optimum conditions for the establishment of problem vegetation. As these disturbed areas are also subject to erosion, planting of low-growing perennial vegetation, turf, or surfacing with crushed gravel underlain with landscape fabric will be undertaken where feasible. 2.6 Identification of Species [IPMR Section 58(2)(ii)] 10

The accurate identification of vegetation on or adjacent to KMC facilities is important for several reasons: Depending on their growth rates and characteristics, and on their physical location, they may become problem vegetation; Control methods for problem vegetation within a facility may differ depending on the species. For example, green areas throughout the facilities will be maintained grassed areas. These vegetated green areas (primarily grass species) are retained to provide competition to the establishment of problem vegetation. Any graveled areas within the facilities should be free of any plant species, so grass species would be treated within graveled areas only. Certain brush and shrubs, depending on their growth habits, may limit access to site and create allow for the addition of seeds and organic materials within the facilities. Vegetation management treatments at KMC facilities will target mainly herbaceous and woody species because they are most problematic when encroaching into facilities, facility fences and perimeter areas. This will include inside and outside perimeter fences that could act as seed sources. Herbaceous grasses and broadleaf weeds are of greatest concern, some of which are designated as noxious or invasive within British Columbia (See Section 3 of this IVMP for further details on noxious and invasive plant control). There are numerous publications that will assist in the identification of problem vegetation. Table 2 indicates the web sites where information on the identification and management of tree, shrub and weed species can be accessed. Table 2: Web Sites for Identification of Tree, Shrub, and Problem Vegetation Species BC Ministry of Forests, Lands, and Natural Resource Operations BC Ministry of Agriculture Tree Identification Field Guide to Noxious and Other Selected Weeds of BC http://www.for.gov.bc.ca/hfd/library/docum ents/treebook/index.htm http://www.agf.gov.bc.ca/cropprot/weedgui d/weedguid.htm WeedsBC Weed Profiles http://www.weedsbc.ca E-Flora BC Electronic Atlas of www.eflora.bc.ca plants of BC KMC vegetation management contractors shall be responsible for the correct identification of problem vegetation at each facility where vegetation management is proposed. 2.6.1 Types of Problem Vegetation at Facilities As was stated in section 2.0, vegetation management programs at KMC facilities targets problem vegetation, noxious weeds and invasive plants. Problem vegetation includes herbaceous grass and broadleaf weeds, woody tree and shrub species. Problem vegetation is a primary concern when it is growing adjacent to piping, buildings, parking areas, and perimeter fences. 11

Herbaceous Grass and Broadleaves Herbaceous broadleaf and grass species are the most frequent types of problem vegetation growing within and immediately adjacent to facilities, and in other areas where the crushed rock or gravel base is very thin and there is exposed subsoil. The dry, gravel surfaces typical of KMC facilities mimic the disturbed conditions where problem vegetation frequently establishes. Control of herbaceous vegetation is also required along access roads, through cracked asphalt, at edges of buildings and along sidewalks in concrete seams. Woody Vegetation Woody tree and shrub species are most problematic when they encroach on facility perimeter fences, or are found in areas where their presence: Limits visibility or access to a site; Presents a safety hazard if they blow down into a facility; Increases the fire hazard potential if they blow down into the facility or are overhanging too close to sensitive equipment; Impacts site security by providing easier access over security fencing; or, Can cause the deposition of organic debris into facilities that increases the growth or establishment of problem vegetation. Noxious Weeds and Invasive Plants Noxious weeds and invasive plants have been identified and found throughout the KMC IVMP area, including within a number of facilities, and on properties adjacent to these facilities. Noxious weeds and invasive plants can negatively impact agriculture, where they can displace or reduce the quality and quantity of crop and forage species. They can also out-compete native plant species, thereby reducing biodiversity and wildlife forage. Control and spread of weeds designated as noxious within British Columbia is legislated under the BCWCA and BCWCR. Within this Act and Regulations, certain weed species are classed as noxious within all regions of the province. In addition, other weed species are designated as noxious weeds within the boundaries of listed regional districts. The control and spread of invasive plants is also legislated under the BCFRPA, Invasive Plant Regulations. The KMC noxious weed and invasive plant IVM program will be described in Section 3 of this IVMP. 2.6 Monitoring Program for Problem Vegetation at Facilities [IPMR Section 58(2)(c)] Treatment of weeds at KMC facilities may become necessary when: Vegetation growth reaches a certain level (i.e., the injury (treatment) threshold); Areas that must be kept free of all vegetation show visual evidence of weeds being present (e.g., under or adjacent to piping); or Vegetation growing on the perimeter of facilities is compromising site safety and security or is creating a fire hazard. 12

Monitoring of facilities provides a record of information about weed occurrence (by species), density, and site conditions. Monitoring includes recording information such as changes to weed species composition, distribution, and density over time, as well as changes to adjacent plant communities that could invade the facility. Monitoring is generally done visually, and documented in writing. 2.6.1 Monitoring Methods Monitoring consists of regular inspections to determine the extent of problem vegetation within and adjacent to facilities. This monitoring provides the information needed to decide whether treatments are necessary (i.e., exceeding the treatment threshold), the best timing of treatments, and the best treatment option. Successful IVM programs are based on regular inspections for the presence and extent of problem vegetation. Inspection frequency should address the level of risk imposed by the nature of activities. Monitoring specific to this IVMP will be conducted by a vegetation specialist. Annual baseline weed assessments will be conducted for all facilities. These assessments will be used to assist the vegetation specialists in determining Treatment Thresholds and be used to determine if the short and long term objectives of the IVMP are being achieved. These baseline weed assessments can be conducted in concert with weed control efforts. Areas of increased risk potential, newly constructed or disturbed areas within and adjacent to facilities will be specifically monitored for problem vegetation. Monitoring is generally carried out on foot or by vehicle, depending on the terrain. Aerial extents of problem vegetation will be expressed as a density distribution for facilities, including within 2 meters of perimeter fences. If problem vegetation is observed, information will be recorded on the pre or post inspection monitoring forms (Appendix 3 and Appendix 4, respectively). The inspection forms are required so that problem vegetation distribution density present can be compared to the treatment threshold (aids management decision making), and will serve as a basis of comparison when conducting a treatment evaluation. The pre and post treatment forms will be used to document infestations over time and assist with direction of weed control contractors. In addition to recording problem vegetation on site, vegetation specialists will document weed species and distribution that may occur within adjacent lands to the facilities to address the concern or threat of the spread of weeds. 2.6.2 Frequency of Monitoring Incidental Monitoring At all facilities, monitoring will be conducted at least two times during the growing season or as frequent as KMC personnel or vegetation specialists determines inspections to be warranted, based on available and effective strategies until infestations have been reduced to below threshold levels. During some of these inspections, incidental monitoring of vegetation presence and populations will be observed. Areas on the perimeter of facilities, including fence lines, may also be inspected. Subsequent inspections will observe any changes that have occurred since the previous inspection. 13

Pre-Treatment Site Monitoring In the spring of each year, a qualified environmental professional will conduct pre-treatment site monitoring at all current KMC facilities. If additional facilities are established, as required for operational purposes, along the existing or upgraded KMC pipeline system within the geographic boundaries of the IVMP area, pre-treatment site monitoring of these additional facilities will also be conducted. All the data collected and recorded during pre-treatment site monitoring will be used by KMC employees to make decisions on the necessity of treatment (i.e., have the injury or treatments levels for vegetation been exceeded), and to decide on the best treatment option(s) from those described in this document. The data collected during this monitoring will be compared to the data collected and documented in the fall of each year at facilities where vegetation management has been conducted (post-treatment monitoring form). Further information on the data collected and recorded during the pre-treatment site assessments/monitoring will be described in detail in Section 2.6.3. 2.6.3 Data Collected During Pre-Treatment Site Monitoring The following information is collected and recorded during the spring pre-treatment monitoring of each facility that is carried out by the qualified environmental professional: Weed species observed, their growth stage, height, density, designation (restricted, noxious, nuisance), and plant category (degree of aggressiveness); Sketch of facility showing distribution of weeds; Location of environmental features requiring protection (e.g. water sources, water bodies, riparian areas) and recommended protection measures; and, If treatment thresholds have been exceeded, treatment options and the rationale for each option recommended. Weed density distribution codes for specific species of problem vegetation will be ranked according to codes assigned by the BC Ministry of Forests, Lands and Natural Resource Operations. This Weed Density Distribution Codes are shown in the KMC Facilities Pre- Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants in Appendix 3 of this document. 2.7 Treatment (Injury) Thresholds [IPMR Section 58(2)(d)(i),(ii)] Treatment of vegetation at KMC facilities is required when the vegetation reaches a certain level. This level is termed the injury threshold (also called an action or treatment threshold). Decisions on treatment are based on the results of the monitoring program. The KMC Regional Coordinator/Environmental Specialist or third party consultant will make decisions on the necessity of treatment and will recommend the best treatment option(s) from the options described in the IVMP. With the exception of noxious weeds (BCWCA and the BFRPA, Invasive Plant Regulations) and the BC Wildfire Regulation, there are no legislated standards related to treatment (injury) thresholds for industrial sites such as KMC facilities. The following information on treatment 14

(injury) thresholds has been derived from generally accepted industry standards for vegetation management in North America. 2.7.1 How Treatment (Injury) Thresholds are Chosen The treatment (injury) threshold is generally the level of surface vegetation cover, expressed as a percentage of the total area, that can be tolerated and still maintain integrity, security and safety within the facility. Any percentage vegetation cover above the established threshold requires a vegetation management action or decision. Treatment (injury) thresholds will vary, since vegetation control is more critical for certain areas within a facility than others. They are generally specific to all species of vegetation (e.g., under and alongside piping and control structures where there is a low tolerance for all vegetation growth). In some instances, the level of surface weed coverage cannot be used to determine if the treatment (injury) threshold has been reached. For specific weed species growing adjacent to facilities, such as tall-growing tree or shrub species that may compromise site security and safety, such factors as the likelihood of the tree or shrub falling onto piping, buildings or critical equipment may be used to determine at what point the injury threshold has been reached. Consequently, the level of control required is determined by: The amount (density) of vegetation; or, Specific species of problem vegetation. Amount of Vegetation In areas where tolerance for vegetation is low, the treatment (injury) threshold is determined by the total amount of vegetation and dead organic matter present at the site. This amount is specific to certain defined areas within a facility. For example, areas under or adjacent to piping, adjacent to diesel fuel or propane tanks, pump house buildings, valve vaults, electrical control buildings, emergency generator units, switchgear buildings, storage buildings for flammable materials, fuel and relief tanks and other control equipment would have a lower action threshold than gravel parking areas, vacant areas and outdoor equipment storage areas. A vegetation management action will be taken when the action threshold for a particular facility or defined area within a facility has been exceeded. Types of Problem Vegetation Some types of vegetation can cause more damage than others. The degree of risk will depend on the management objectives for a particular area. All woody and tree species, noxious weeds and invasive plants, and difficult to control species are generally placed in the high risk category because some species of vegetation could grow into or around sensitive equipment (system safety and fire hazard) or could damage equipment by falling (trees). Noxious weeds and invasive plants must be controlled as mandated by the BCWCA and BCWCR, if an inspector under this act deems the presence of the noxious weed to be a threat to adjacent agricultural areas. Some species of problem vegetation are aggressively growing and could compromise site security by growing through fencing, and will increase the amount of organic matter on the site, are deep-rooted species, or are difficult to control. 15

The growth of low risk species of vegetation is beneficial in certain areas within and adjacent to facilities. Low risk species include low growing herbaceous grasses and forbs (broadleaf herbs) and moss. Benefits of maintaining low risk vegetation growing outside of fences and in certain areas within facilities include providing plant competition against the establishment of aggressively growing species, reducing soil erosion, absorbing ground water flowing from inside the facility, and improving site aesthetics. Allowing low risk vegetation to establish in vacant areas within facilities also effectively reduces the overall gravel area requiring vegetation management. Moss growing on gravel areas can also provide plant competition against species of problem vegetation All data collected will be saved to KMC s database and will be used to aid vegetation specialists and herbicide applicators to determine site risk levels for facilities. This information will be reviewed annually. As was discussed in section 2.6.3, weed density distribution codes for specific species of problem vegetation will be ranked according to codes assigned by the BC Ministry of Forests, Lands and Natural Resource Operations. This Weed Density Distribution Codes are shown in the KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants in Appendix 3 of this document. 2.7.2 How Treatment (Injury) Thresholds are Applied The amount (density) of problem vegetation and its location (type of facility or specific location within a facility) are the primary injury thresholds that will be applied in making vegetation control decisions. This will also include the presence and location of hazard trees that may fall or grow into the facility. Vegetation control does not follow established management cycles, as the decision to initiate control measures is based on the above factors. 2.7.3 Specific Injury (Treatment) Thresholds Treatment (injury) thresholds have been established for specific types of weed problems found at KMC facilities. These thresholds specifically relate to: Invasive plants and noxious weeds (discussed in section 3.0); Thresholds established to meet regulatory requirements; Thresholds for areas within facilities that have no legislated requirement for control; and, Thresholds for vegetation, including trees and shrubs, growing along the perimeter fences. 2.7.3.1 Invasive Plants and Noxious Weeds Injury thresholds for invasive plants and noxious weeds will be discussed in Section 3 of this IVMP. 2.7.3.2 Thresholds Established to Meet Regulatory Requirements BC Wildfire Regulation (BCWR) and the Onshore Pipeline Regulations mandate vegetation management in certain areas or for certain specific reasons. Neither of these pieces of legislation, however, specifies quantitative standards (i.e., treatment (injury) thresholds based on the amount of vegetation present). In order to be in compliance with these pieces of legislation, KMC will set appropriate treatment (injury) thresholds for vegetation management based on individual assessments of vegetation at each of their facilities. These will be based on 16

plant category (degree of invasiveness and site risk levels) described in section 3.6.2 and in Appendix 3. BC Wildfire Regulation The BCWR mandates vegetation management in certain areas, or for certain, specific reasons. Section 7 of the BCWR states that: A person carrying out an industrial activity that is refuse disposal, wood sorting, wood milling, wood processing or wood manufacturing, or operating a camp with that activity or any other industrial activity on a site that is on or within 300 meters of forest land or grass land must maintain a sufficient fuel break at or near the site to ensure that a fire originating at the site does not escape the site. When constructing new facilities, KMC has a policy that requires that all vegetation be removed from the perimeter for fire prevention reasons. As noted earlier, however, tall growing trees and shrubs can become established in these areas during the production life of the facility. In order to ensure compliance with Section 7 of the BC Wildfire Regulation, this may require the removal of vegetation and/or topsoil, in order to maintain a sufficient fuel break. Facilities will be assessed on an individual basis with respect to establishing injury thresholds for vegetation that may have to be removed around facilities in order to maintain a sufficient fuel break. Onshore Pipeline Regulations Section 39 of the Onshore Pipeline Regulations (National Energy Board) states: A company shall develop a monitoring and surveillance program for the protection of the pipeline, the public and the environment. Part of this requirement requires that a company develop and implement an environmental protection program to anticipate, prevent, mitigate and manage conditions that have a potential to adversely affect the environment (section 48). One of the components of this environmental protection program is to have a process (consistent with ISO 14000 standards and provisions of CSA Z662) for managing vegetation. 2.7.3.3 Non-Legislated Areas Within Facilities Specific injury thresholds for specific areas within KMC facilities are detailed in Table 3. These injury thresholds have been derived from generally accepted industry standards and practices: Table 3: Treatment (Injury) Thresholds for Specific Sites Within a Facility Specific Sites Within a Facility All areas under piping All areas with 4 meters of piping, diesel fuel, jet fuel B or propane storage tanks, pump house buildings, valve vaults, electrical control buildings, emergency generator units, switchgear buildings, storage buildings for flammable materials, fuel Injury Threshold 0% (no vegetation allowed). 0% (no vegetation allowed). Presence of any vegetation requires a vegetation management decision. 17

and relief tanks, and other areas or buildings used for control equipment and operational requirements Helicopter pads Within electrical substations and within 2 meters outside their perimeter fences Undeveloped areas (no buildings or equipment) within a facility Perimeter fences Paved parking areas within facilities Unpaved parking areas within facilities Ministry of Transportation clearance requirements are: 0% - (no vegetation allowed) within a 5 meter radius of the passenger and equipment exit zone; 100% - All trees and tall-growing vegetation within a 15 x 15 meter radius must be removed; and, 100% - All trees and tall-growing vegetation within a 44 x 44 meter radius must be removed, depending on terrain, to ensure rotor clearance and maneuvering room. 0% - (vegetation covering greater than 5% by unit area requires a vegetation management decision). 10% - (vegetation covering greater than 10% by unit area requires a vegetation management decision). Grass growing in these areas can exceed the 10% surface cover threshold provided that is maintained at a level below 10 cm in height 10% - (vegetation covering greater than 10% by unit area requires a vegetation management decision). All tall growing tree and shrub species growing within 1 meter of fences will be selectively controlled. Low-growing herbaceous vegetation is allowed within 1 meter of fences, provided that they are regularly maintained and do not exceed a height of 15 cm. 5% - (vegetation covering greater than 5% by unit area requires a vegetation management decision). 10% - (vegetation covering greater than 10% by unit area requires a vegetation management decision) - to ensure vehicle access and to prevent fire hazards. 2.8 Vegetation Management Options [IPMR Section 58(2)(e)] 18

IVM involves the use of different techniques to control undesirable vegetation within and adjacent to facilities. The selection of a treatment option(s) will depend on the species of vegetation to be targeted, treatment timing, land use and environmental sensitivities of surrounding areas. These site conditions have been recorded in a KMC document entitled KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants (Appendix 3). KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants This document has been prepared for all KMC facilities covered under this IVMP by a qualified environmental professional. It is provided to, and discussed with, vegetation management contractors prior to treatment, and includes both the chemical and non-chemical treatment options that may be used at a particular facility. It is KMC policy that chemical control options (herbicides) will not be considered for any facility until this monitoring form has been completed for this facility. The information described in the KMC Facilities Pre-Treatment Weed Monitoring Form for problem Vegetation, Noxious Weeds and Invasive Plants includes: Facility location, size, and site security (fenced or not fenced); Facility description, including site conditions, including slope and aspect of site, drainage, water sources on site and climate; Within the facility Existing vegetation type, density and location, vegetation concerns, specific management prescriptions, recommendations, and timing; Outside the facility Existing vegetation type, density and location, vegetation concerns, specific management prescriptions, recommendations, and timing; Existing vegetation concerns; Specific vegetation management recommendations/options; Distance from the facility perimeter to water bodies, water intakes and wells; Location and description of environmentally sensitive areas and suggested or required (i.e. by legislation) pesticide free zones (PFZ s) and no treatment zones (NTZ s) for their protection; Adjacent land uses (i.e., residential, agricultural, industrial, commercial); and, Prominent adjacent vegetation (i.e., grassland, forest, pasture, crop land, lawn, landscaping). Since a wide variety of vegetation types regularly grow within, or adjacent to, KMC facilities, a single treatment option is generally not suitable for all species. An integrated approach combining chemical and non-chemical control options is generally most effective when tailored to the vegetation concerns and conditions at each facility. Various non-chemical and chemical vegetation control methods may be used at KMC facilities. The information in the following section will describe: The non-chemical control methods that may be used for controlling vegetation; The rationale/selection criteria for treatment method(s) selection; The benefits and limitations of each non-chemical treatment method; and, A description of how a decision to use a non-chemical treatment method will be made. 19

Note: Herbicide identification, use areas, properties and use patterns, application methods/techniques (including rationale/selection criteria, benefits and limitations for each herbicide), and equipment for all herbicides proposed for use under this IVMP for vegetation management at facilities will be discussed in sections 3.7.3 and 4.7 of this IVMP. KMC may use non-chemical (manual and mechanical and cultural) and chemical (i.e. herbicide) vegetation control methods/techniques within this IVMP for facilities vegetation management. These are listed in Table 4: Table 4: Vegetation Management Options, Methods and Techniques for Vegetation Management Manual and Mechanical (Non-Chemical) Girdling (frilling) Pruning Hand pulling Geotextile fabric Mowing Tree & stump removal Weed trimming Selective slashing Cultural (Non-chemical) Seeding & Planting Grasses Irrigation and Fertilization Retaining existing ground cover Herbicide Applications (Chemical) Cut surface Basal bark Foliar Soil Wick/wipe-on 2.8.1 Manual and Mechanical (Non-Chemical) Control Options at KMC Facilities [IPMR Section 58(2)(e)] The following information describes the currently available manual and mechanical options for controlling problem vegetation at KMC facilities. This list may not be wholly inclusive and does not prohibit the ability of KMC to utilize other generally accepted non-chemical methods of control. As was noted in section 2.7.2, the exclusive use of manual and mechanical (non-chemical) methods to control problem deciduous vegetation often provides only temporary control and may compound the vegetation problem by encouraging multi-stem regeneration. Therefore, for deciduous vegetation, manual and mechanical techniques may be combined with chemical controls (i.e. herbicides) to inhibit re-sprouting. A description of and rationale and selection criteria, and the benefits and limitations of manual and mechanical methods of vegetation control at KMC facilities are shown in Table 5. Table 5: Description of, Rationale and Selection Criteria for, and Benefits and Limitations of Manual and Mechanical (Non-Chemical) Control Methods for Vegetation Management at KMC Facilities Description & Rationale/Selection Criteria Girdling involves cutting a strip of bark (and tissue) down to the Benefits and Limitations The advantages of girdling are that it can be used to control individual tree species in any terrain. Grinding selectively 20

sapwood from around the entire tree trunk with an axe or other hand tool. The above ground parts continue to grow, but the roots starve and the tree slowly dies. The dead tree is cut down or slowly left to die, which may take 2 to 3 years. Pruning is the selective removal of plant parts using proper arboricultural techniques. It is useful for the removal of limbs and branches from large native trees and domestic shrubs growing along facility perimeter fences. Tree pruning can be used where tree removal may not be appropriate. Hand Pulling is a viable physical control only for certain established weeds than can be easily uprooted such as young tree seedlings and clumps of grass where the roots can be fully removed. It is effective if the number of weeds to be pulled is small and the site is a manageable size. When hand pulling is used to manage weeds, the exposed soil should be immediately covered with gravel or seeded to allow desirable species to establish. Geotextile is a porous, polypropylene fabric that is generally placed below mulches, crushed rock or gravel. It can be used in landscaped areas trees or shrubs have been planted within facilities. It works as a physical barrier preventing root growth of the unwanted vegetation through the fabric. removes individual trees, the growth and retention of lowgrowing vegetation cover are promoted, and site stability is maintained. It is particularly effective on birch, willow and alder, and on small maple species where the root collar is small and there are less than 5 stems. Girdling is a useful technique to selectively manage encroaching tree species outside facility perimeter fences, especially in areas adjacent to bodies of water or other environmentally sensitive areas where pesticides cannot be used. The limitations (disadvantages) of girdling are that because the trees remain standing for 2 to 3 years after girdling, they can become a fire hazard. Girdling is also labour intensive, costly, and, if done incorrectly re-sprouting of deciduous vegetation can occur. The advantages of pruning on facility perimeter fences are that it may influence the direction of branch growth and may eliminate the need to remove problem trees that are interfering with site security and access. Unlike other manual/mechanical control methods, pruning does not adversely affect wildlife habit, biodiversity or aesthetics. The limitations (disadvantages) of pruning are that it may have to be repeated at regular intervals, it is costlier and more labour intensive than other manual/mechanical methods. Knowledge and experience of proper arboricultural techniques are need for successful pruning. Improper pruning can cause tree damage and can result in unsightly, unhealthy and hazardous trees that may require further remedial action. The advantages of hand pulling are that it can be used in areas where there has been little or no vegetation management undertaken for an extended period of time, hand pulling can be effective in reducing a large volume of vegetation to a manageable level. Removal of seed source can aid in the suppression of infestations. The limitations (disadvantages) of hand pulling are that it is labour intensive, and that excessive hand pulling of weeds tends to increase the amount of organic matter or exposed soils, which can encourage weed establishment. Seeding after manual removal is highly recommended. The advantages of using geotextile fabric are that their use has the potential to reduce the need for other control methods for vegetation management. The limitations (disadvantages) of using geotextile fabric are that the initial placement of geotextile fabric can be labour intensive. 21

Mowing is the cutting of problem vegetation within facilities, primarily grasses or other low growing herbaceous species. Vegetation can be mowed using equipment such as commercial lawnmowers, industrial tractors or garden tractors/mowers. Tree and Stump Removal is the removal of large, mature trees. It may be required adjacent to facilities to improve site safety, security and aesthetics. Selective Slashing (brushing) is managing individual woody trees and shrub species that are encroaching on facility perimeter fences. For deciduous vegetation, it will generally be followed by the application of herbicides to the cut surface to inhibit re-sprouting. Weed Trimming is used for removing herbaceous vegetation growing on gravel areas, within cracks in asphalt or concrete, within landscaped areas and along facility perimeter fences. Weed trimming with a follow-up herbicide application. The advantages of mowing include controlling vegetation before it goes to seed, thus reducing the seed source available for dispersal to other areas of low vegetation tolerance within the facility. Mowing promotes aesthetics and is economical. Mowing is useful for maintaining vacant or undeveloped areas within a facility. The limitations (disadvantages) of mowing are that it is not suitable in areas that are rocky, on slopes, or where low-growing compatible species predominate. Mowing certain weed species can vegetatively stimulate invasive weed species causing matting or areas of prolific grow of undesirables. It promotes the resprouting of deciduous vegetation, resulting in the need for future treatments or herbicide applications to inhibit resprouting. There are some safety issues due to flying debris. Mowing generally is very labour intensive, as it has to be done several times at each location during a growing season. The advantages of tree and stump removal include being able to control individual tree species in any terrain. As it selectively removes individual trees, the growth and retention of low-growing vegetation are promoted, and site stability is maintained. Stump and tree removal is often required following tree cutting if the stump is unsafe, aesthetically displeasing, or is in a construction location where danger trees are required to be removed. Removal in construction sites is achieved with heavy machinery. Individual stumps can be ground down with a stump grinder. The limitations (disadvantages) of tree cutting and stump removal are that it is expensive and labour intensive. Chain saws, hand tools and falling trees can pose safety hazards. Deciduous stumps must be removed, ground down, covered or treated with herbicide to prevent re-sprouting. Unless costly cleanup is completed, there can be negative aesthetics. The advantages of selective slashing (brushing) are that it is species specific, enables desirable vegetation to be left, creates little soil disturbance, and has little effect on biodiversity. It is useful for deciduous vegetation control, as it allows the follow-up selective application of herbicides to cut surfaces to inhibit re-sprouting. The limitations (disadvantages) of selective slashing (brushing) are that can pose safety hazards to the operators and bystanders. It is also very labour intensive and expensive. The advantages of weed trimming are that it helps to remove seed heads when done early in the season, and is convenient and economical. The use of weed trimmers is generally more suitable than mowers for use in areas that are rocky, have stumps, on slopes, where low-growing compatible species predominate, or are not accessible to lawnmowers or tractors. The limitations (disadvantages) weed trimming are that it does not remove roots, and has only limited effectiveness on species that reproduce from stem pieces. There are some safety risks due to flying debris. 22

2.8.2 Cultural (Non-Chemical) Control Options at KMC Facilities [IPMR Section 58(2)(e)] Cultural control options may include seeding and planting grasses, irrigation and fertilization, and retaining existing ground cover. A description of and rationale and selection criteria, and the benefits and limitations of these cultural control options is shown in Table 6: Table 6: Description of, Rationale and Selection Criteria for, and Benefits and Limitations of Cultural Control Methods for Vegetation Management at KMC Facilities Description & Rationale/Selection Criteria Seeding and Planting Grasses involves re-vegetating bare/disturbed ground and landscaped areas in facilities with a suitable mixture of species compatible to the surrounding land capability and use. This method involves the planting of certified grass seed that will reduce the risk of problem vegetation becoming established. Irrigation and Fertilization refers to the fact that problem vegetation in facilities responds positively to increased water and nutrients. The key to using irrigation and fertilization as tools for effective control of problem vegetation is to first control the problem vegetation and then use irrigation and fertilization to promote the growth of competing, non-problematic vegetation that is planted. Retaining Existing Low Ground Cover involves leaving existing lowgrowing plant species undisturbed as much as possible during the construction of new facilities, or when mechanically removing problem tallgrowing vegetation. During the construction of new facilities, or when Benefits and Limitations The advantages of seeding and planting grasses are that it prevents erosion, inhibits weed establishment and growth, and promotes aesthetics. Maintaining grasses at a level of 7.5 cm, combined with proper fertilization, provides a dense growth of grass that will inhibit the introduction and growth of weeds. Another side benefit is that some grass species can better withstand drought conditions in the summer. The limitations (disadvantages) of seeding and planting grasses are that it requires continued maintenance (i.e. mowing), does not provide a stable plant community because unwanted species may invade, and the sustained promotion of grasses as a monoculture in sites adjacent to forested areas may pose a fire hazard. The advantages of using irrigation and fertilizing following the seeding of appropriate competitive forage species or erosion control mixes can result in reduced levels of problem vegetation establishment by increasing competition. The only limitation (disadvantage) of irrigation and fertilization is that in order to effective, the problem vegetation must have been eliminated from a site prior to the use of irrigation and fertilization. The advantages of retaining existing low ground vegetative cover will generally result in physical controls and chemical controls only being applied to targeted problem vegetation in these areas. Disturbances to the surrounding low-growing vegetation will be minimized, allowing the competitive plants to out-compete the problem species. The only limitation (disadvantage) on retaining existing low 23

mechanically removing problem tall growing vegetation, the existing lowgrowing plant species will be left undisturbed as much as possible. ground cover is the initial cost of establishing the lowgrowing competitive vegetation. 2.8.3 Chemical Control Options (Herbicides) at KMC Facilities [IPMR Section 58(2)(e)] The selective and limited use of herbicides is an important part of the KMC IVM program within and adjacent to facilities. An IPM program that combines the manual/mechanical/cultural methods discussed earlier with the site specific use of herbicides is often the only effective way to establish a stable, low-growing plant community. Manual/mechanical/cultural control methods used alone will not keep deciduous vegetation below injury thresholds over the long-term due to re-sprouting. In addition, herbicides may be required to target specific plant species and complexes within facilities, primarily noxious weeds and invasive plants, as well as other grasses and herbaceous broadleaf plants growing on gravel areas. The Need for Herbicides The use of herbicides at KMC facilities may be required for: Vegetation control in areas where non-chemical methods are not feasible or practical; Control of deciduous vegetation to control re-sprouting; and, Control of noxious weeds and invasive plants where manual and mechanical control methods are not effective or practical. This will be discussed in section 3.0. Herbicides Proposed for Use to Control Problem Vegetation at Facilities Herbicide identification, use areas, properties and use patterns, application methods and techniques (including rationale/selection criteria, benefits and limitations for each herbicide), and equipment for all herbicides proposed for use under this IVMP for the control of problem vegetation at KMC facilities will be further discussed in section 4.7 of this IVMP. Additional active ingredients that may be used for the management of noxious weeds and invasive plants at facilities will be discussed in Section 4.7 of this IVMP. 2.9 Treatment Selection Criteria [IPMR Section 58(2)(e)] IVMP involves a decision-making process that looks at the various treatment options that are available for any particular vegetation complex. This decision-making process ensures that the most suitable, effective, environmentally compatible and cost-effective method or combination of methods is selected for a particular facility, a vegetation management complex within part of a facility, and perimeter fences. In making these decisions, KMC personnel and contractors will generally use the following assessment criteria to justify and evaluate the method(s) chosen: 24

Urgency of the required treatment (e.g., prohibited invasive plant, a legislative requirement, required for access to an area, or concerns for facility safety or security) and consequences of not taking action; Species and location of the problem vegetation; Accessibility to the problem vegetation; Safety issues with KMC personnel, contractors or the public; Risk of fire (fuel loading on the ground); Objectives of the vegetation management program; Density and height of the problem vegetation; Effect on adjacent property owners (e.g., agricultural land); Aesthetic considerations (plan holder reputation and community standing); Short and long-term impacts of the method(s) being considered; Expected efficacy of the method(s) being considered; Benefits and limitations of each method; Cost effectiveness of each method; Environmental considerations (proximity to water sources, bodies of water, food growing or planted for human consumption, riparian areas, wildlife and fish habitat, grazing restrictions, re-entry intervals based on product applied); and, For herbicide treatments, the choice of herbicide, application methods/techniques and application equipment. 2.10 Post-Treatment Monitoring/Evaluations [IPMR Section 58(2)(f)] Qualified contractors in possession of a valid Pesticide User License will conduct all herbicide applications. All herbicide applications will be made by Certified Pesticide Applicators in the Industrial Vegetation and Noxious Weed category, or supervised by certified pesticide applicators in the appropriate category of certification. KMC or a qualified environmental professional will inspect and evaluate representative samples of sites to which herbicides have been applied to determine: Compliance with the commitments made in this IVMP; Compliance with the IPMA and IPMR; That site objectives have been achieved; The success of the treatment methods employed; If pesticide free zones, no treatment zones and buffer zones were maintained; If environmental features requiring protection were adequately protected; If any negative environmental impacts have occurred; and, If corrective action is required. Post-treatment monitoring will be conducted at least two times during the growing season at all facilities to which herbicides have been applied, or as frequent as KMC personnel or vegetation specialists determines inspections to be warranted based on available and effective strategies until infestations have been reduced to below threshold levels. 25

All inspection results will be documented in the KMC Post-Treatment(s) Monitoring Form shown in Appendix 4. The following information is recorded on the KMC Post-Treatment Monitoring Form: Date of inspection/inspector; Description and location of site inspected; Date of herbicide(s) and/or non-chemical treatment(s); Herbicide(s) applied, application rate, and area treated; Licensed contractor and certified applicator in attendance; Post-treatment inspection observations, including weather conditions during treatments, confirmation of Treatment Notice posting, and visual signs of off-target damage to adjacent vegetation. Photographs will be taken at each facility inspected and included in the monitoring form; Environmental features requiring protection and environmental protection measures taken; Treatment efficacy, and whether site objectives were achieved; Comments and recommendations; and, Compliance with the IPMR commitments made in this IVMP. 3.0 THE KMC IVMP FOR NOXIOUS WEED AND INVASIVE PLANT MANAGEMENT PROGRAM AT FACILITIES This section deals specifically with the objectives and steps for managing both noxious weeds and invasive plants at KMC facilities area using the principles of IPM. 3.1 Noxious Weeds Noxious weeds impact agriculture where they displace or reduce the quality of crop and forage species and natural environments. They also out-compete native plant species, reducing biodiversity and forage for wildlife. Noxious weeds are plants that are typically introduced from other countries without their natural predators and pathogens that would normally keep them in check. They are generally very invasive, aggressive plants that are capable of colonizing areas and replacing desirable native vegetation. The BCWCA defines a noxious weed as a weed designated by regulation to be a noxious weed, and includes the seeds of the noxious weed. The control and spread of weeds designated noxious within British Columbia is legislated under the BCWCA and BCWCR. Within this Act and Regulations, certain weeds are classed as noxious within all regions of the province. In addition, other weeds are designated as noxious weeds within the boundaries of listed regional districts. The current (2015) provincial and regional noxious weeds are listed in Table 7: Table 7: Current Provincial and Regional Weeds Designated by Regulation as Noxious Under the BC Weed Control Act and Regulations (2015) 26

Provincial Weeds Annual Sow Thistle Canada Thistle Common Toadflax Diffuse Knapweed Flowering Rush Giant Knotweed Himalayan Knotweed Jointed Goatgrass North Africa Grass Purple Nutsedge Scentless Chamomile Tansy Ragwort Yellow Flag Iris Regional Weeds Fraser Valley Regional District Wild Chervil Bohemian Knotweed Common Crupina Dalmatian Toadflax Dodder Garlic Mustard Giant Mannagrass/Reed Sweetgrass Hound s-tongue Leafy Spurge Perennial Sow Thistle Rush Skeletonweed Smooth Cordgrass Velvetleaf Yellow Nutsedge Bur Chervil Common Reed Dense-flowered Cordgrass English Cordgrass Giant Hogweed Gorse Japanese Knotweed Milk Thistle Purple Loosestrife Saltmeadow Cordgrass Spotted Knapweed Wild Oats Yellow Starthistle Thompson-Nicola Regional Fraser-Fort George District Regional District Blueweed Burdock Burdock Marsh Plume Thistle Field Scabious Hoary Cress Orange Hawkweed Oxeye Daisy Perennial Pepperweed Sulphur Cinquefoil These weeds are designated as noxious within the boundaries of the IVMP area (i.e. Fraser Valley, Fraser-Fort George and Thompson-Nicola Regional Districts). There are no weeds designated as noxious within the Greater Vancouver Regional District. 3.2 Invasive Plants The Invasive Species Council of BC defines invasive plants as any invasive alien plant species that has the potential to pose undesirable or detrimental impacts on humans, animals or ecosystems. (2014). Invasive plants are plants that are non-native or alien to the ecosystem under consideration. Their introduction causes, or is likely to cause, economic or environmental damage, or harm to human health. In B.C. the term invasive plant is synonymous with invasive alien plant. These plants threaten the natural environment and are recognized globally as the second greatest threat to biodiversity. Free from the plant pests that keep them in check in their native ranges, invasive plants reproduce rapidly and spread aggressively, dominating natural areas and altering biological communities. The result of these invasions can include reduced recreation and crop values, damaged infrastructure, displaced native vegetation that is important forage for wildlife and livestock, reduced biodiversity including species at risk, and damaged native ecosystems. Species of invasive plants may be listed under the BCWCA and BCWCR may also be listed under the BCFRPA, Invasive Plant Regulation. 27

For the purposes of this IVMP, invasive plants will be considered as those plants identified by the BC Ministry of Forests and Range, Invasive Plant Advisory Committee to be impacting plant communities and that require treatment. These plants will, for the most part, coincide with those listed both within the BCFRPA, Invasive Plants Regulation, and those listed under the BCWCA and BCWCR, but are not limited to these. KMC is an interprovincial pipeline and there may be specific weed species deemed noxious and prohibited noxious in one province (e.g. Alberta) that have a different designation (e.g. nuisance weed) in an adjacent province (e.g. British Columbia). Due to potential travel/movement of these species between these provinces, KMC personnel will adopt the most stringent approach to control of these species to inhibit their establishment in the adjacent province. An example would be a species that is deemed a nuisance in British Columbia and growing near the Alberta border may be targeted for treatment at facilities if the species is deemed noxious or prohibited in Alberta. Table 8 lists the species of invasive plants identified in the BCFRPA, Invasive Plant Regulation. Most of the plants on this list have either been reported within the geographic boundaries of the KMC plan area, or have been documented within adjacent districts or jurisdictions. Table 8: Plants Currently Listed as Invasive Under the Forest and Range Practices Act, Invasive Plant Regulation Anchusa Blueweed Canada thistle Dalmation Toadflax Giant Knotweed Hoary Cress Leafy Spurge Meadow Knapweed Oxeye Daisy Puncturevine Russian Knapweed Scotch Thistle Sulphur Cinquefoil Yellow Iris Baby s breath Brown Knapweed Common Burdock Diffuse Knapweed Gorse Hound s-tongue Marsh Thistle Nodding Thistle Perennial Pepperweed Purple Loosestrife Scentless Chamomile Spotted Knapweed Tansy Ragwort Yellow Starthistle Black Knapweed Bull Thistle Common Tansy Field Scabious Hoary Alyssum, Japanese Knotweed Meadow Hawkweed Orange Hawkweed Plumeless Thistle Rush Skeletonweed Scotch Broom St. John s Wort Teasel Yellow Toadflax 3.3 The KMC Noxious Weed and Invasive Plant Management Program KMC staff will conduct incidental monitoring of noxious weed and invasive plant populations during scheduled patrols, inspections or maintenance activities at KMC facilities. During monitoring, the location, density, growth stage, height, plant category (degree of invasiveness), and site risk level of the noxious weeds and invasive plants observed will be documented in the Pre-Treatment Monitoring Form (See Appendix 3 for a generic copy of this form), and will be discussed further in Section 3.6. KMC recognizes and adopts the system currently used by most agencies of placing noxious weeds and invasive plants (and the sites where they are found) into categories that are used to 28

establish injury (treatment) thresholds and treatment methods and priorities. This is shown in Appendix 5 (Weeds of Management Concern for the Trans Mountain Pipeline System) and will be discussed further in section 3.6 and summarized in Table 10. KMC works cooperatively with adjacent landowners (especially in agricultural areas), regional invasive plant and noxious weed management committees and inspectors appointed under the BCWCA or regulators appointed by the National Energy Board (NEB). When brought to their attention, KMC may provide funding for programs to manage noxious weeds and invasive plants found on their facilities where the cause is attributable to company activity and not poor land use practices by adjacent land owners. This funding is used to retain the services of contractors who are licensed by the BC Ministry of Environment to undertake noxious weed and invasive plant management using pesticides. KMC is actively involved in taking preventative measures aimed at reducing the establishment or spread of noxious weeds and invasive plants at their facilities. They actively encourage their staff, contractors, adjacent landowners and regional noxious weed and invasive plant management committees to report incidences of weed presence on KMC property, and firmly believes in, and practices, working with all stakeholders in partnerships. As part of this approach, KMC has developed a field guide for their staff to assist them in identifying noxious weeds and invasive plants during their work activities and to understand the treatment options available, and the steps that must be followed, for their control. In meeting its corporate responsibility to manage noxious weeds and invasive plants at their facilities, KMC will: Adhere to the principles of IVM in their invasive plant management program; Accept the injury thresholds (treatment thresholds) established by regional noxious weed and invasive plant committees, or the most stringent thresholds between Alberta and British Columbia when determining if control is warranted, control methods to be used, and resource requirements; Require contractors to apply herbicides, if required, in a safe, legal and effective manner; Control invasive plants as mandated by the BCWCA and BCWCR and the BCFRPA, Invasive Plants Regulation; Use the most effective, efficient, and environmentally friendly control options; and, Consider the use of preventative, non-chemical control methods where possible. The IVMP elements that form the basis of the KMC integrated noxious weed and invasive plant management program at their facilities are discussed in the following sections. 3.4 Prevention [IPMR Section 58(2)(a)] KMC will practice and promote the following preventative measures for noxious weed and invasive plant management at their facilities: Re-seeding of bare ground with certified seed at newly constructed facilities or following construction upgrades to existing facilities; and, 29

Preventing the spread to non-infested areas by requiring that vehicles traveling from and to weed infested areas be inspected to ensure that noxious weed and invasive plant parts have not attached themselves to the undercarriage. 3.5 Pest Identification [IPMR Section 58(2)(ii)] The accurate identification of noxious weeds and invasive plants at facilities is important for the following reasons: Control may or may not be required, depending on the plant s growth stage, physical location and degree of invasiveness; and, Control methods may differ depending on the plant species. Some may be easily controlled by non-chemical methods, but others may only be effectively managed through a combination of chemical and non-chemical methods. For noxious weed and invasive plant management, it is important to have a basic understanding of plant biology, including knowledge of growth stages, life cycles and classification, so that the safest, most appropriate and effective control methods may be used. There are numerous publications that will assist in their identification. Table 9 lists the web sites where information on noxious weed and invasive plant identification and management can be accessed. Table 9: Web Sites for Identification of Noxious Weed and Invasive Plant Species BC Ministry of Agriculture Field Guide to Noxious and Other Selected Weeds of BC Fact Sheets on Invasive Plants http://www.agf.gov.bc.ca/cropprot/w eedguid/weedguid.htm Invasive Species Council www.bcinvasives.ca of BC WeedsBC Weed Profiles http://www.weedsbc.ca Southern Interior Weed Invasive Plants of the http://www.siwmc.ca Management Committee Southern Interior of BC Invasive Species Council Invasive Plants of Metro http://www.iscmv.ca of Metro Vancouver Vancouver Fraser Valley Invasive Invasive Plants of Fraser http://www.fraservalleyweeds.com Plant Council Valley 3.6 Monitoring and Establishing Injury (Treatment) Thresholds [IPMR Section 58(2)(c)] 3.6.1 Monitoring Populations As was noted in Section 2.6, KMC staff may undertake incidental monitoring of noxious weed and invasive plant populations during scheduled patrols, inspections or maintenance activities at 30

facilities. In addition, the location, density, growth stage, height, plant category (degree of invasiveness), and site risk level of the noxious weeds and invasive plants observed at each facility during the spring pre-treatment site monitoring program will be documented in the KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants (shown in Appendix 4). 3.6.2 Establishing Injury (Treatment) Thresholds [IPMR Section 58(2)(d)(i),(ii)] In order to effectively and efficiently carry out a noxious weed and invasive plant management program at facilities, it is necessary to categorize the noxious weed or invasive plant (i.e. establish plant categories) and prioritize sites (based on site risk levels). Table 10 shows the categories of noxious weeds and invasive plants of current priority at facilities within the KMC plan area based on visual observations during monitoring. Appendix 5 (Weeds of Management Concern for the Trans Mountain Pipeline System) shows a complete list of weeds of management concern and their category of priority. Table 10: Categories of Invasive Plant Species of Current Priority at KMC Facilities Based on Visual Observations During Monitoring CATEGORY 1 CATEGORY 2 CATEGORY 3 CATEGORY 4 Common bugloss Blueweed Baby s breath Nodding thistle Gorse Canada thistle Batchelor s buttons St. Johns wort Leafy spurge Common tansy Black knapweed Perennial pepperweed Dalmation toadflax Brown knapweed Puncturevine Diffuse knapweed Bull thistle Purple loosestrife Field scabious Burdock spp. Rush skeletonweed Hoary alyssum Common toadflax Spotted knapweed Hound s-tongue Giant knotweed Sulphur cinquefoil Orange hawkweed Hoary cress Yellow starthistle Plumeless thistle Japanese knotweed Scotch thistle Meadow knapweed Tansy ragwort Oxeye daisy Teasel Russian knapweed Yellow hawkweeds Scentless chamomile Yellow iris Scotch broom Category 1 - noxious weeds and invasive plants in this category are extremely invasive and often are the most abundant species in the area. These weeds can be very hard to eradicate. Category 2 - noxious weeds and invasive plants in this category are very invasive and can become very prevalent in an area. These species are also very hard to eradicate. Category 3 - noxious weeds and invasive plants in this category are invasive, but often require some disturbance to establish. Category 4 - noxious weeds and invasive plants in this category are aggressive and relatively easy to control. Native plants that behave in a weedy manner are typically in this category. The above system of categorizing noxious weeds and invasive plants helps with decisions in allocating resources for determining control options. A further refinement is to establish site risk levels (which will assist in assigning site priorities for control). Some of the newly arrived 31

noxious weeds and invasive plant species infest only a few facilities within the KMC plan area. With available resources, it is feasible to keep some noxious weed and invasive plant species from spreading further through the use of preventative measures (as discussed earlier) and by quickly detecting and controlling new infestations that are located by regular monitoring. Some invasive plant species have been observed covering large areas within some KMC facilities. The location of these sites, including their proximity to adjacent areas of high resource value, is normally brought to the attention of KMC during incidental monitoring during patrols and during the spring pre-treatment site monitoring program. The goal for the facilities noxious weed and invasive plant management program is to significantly reduce or eliminate known infestations. KMC generally uses a system to determine site risk levels based on the system currently being used province-wide. This system is described in Table 11. Table 11: Noxious Weed and Invasive Plant Site Risk Levels PRIORITY 1 Extremely High Risk 2 Moderate Risk 3 Low Risk PURPOSE OR INTENT OF TREATMENT To stop the spread of invasive plants threatening non-infested, highly susceptible areas. The priority includes sites that are threatening adjacent agricultural lands (e.g. cultivated, hay and pasture lands), or lands with a high aesthetic value due to their location or proximity to residences or areas frequented by people. To stop the enlargement of sites in highly susceptible areas where there is an expectation of a high level of control. Weedy within facilities will be considered to be a Priority 1 if a vegetation specialist identifies a high potential for the noxious weeds or invasive plants to spread off the site and invade agricultural areas, or if the site is adjacent to transportation corridors such as roads, railways or waterways. To stop the enlargement of sites in less susceptible areas. This includes sites adjacent to lands such as forested lands that have a wellestablished vegetation cover, and are therefore less susceptible to invasive or seed species introduction. Weedy areas within facilities will be considered to be a Priority 1 if a vegetation specialist identifies a high potential for the noxious weeds or invasive plants to spread from the facility and invade adjacent lands. This may include forested areas where vegetation is well established. To stop the enlargement/contain sites on, and adjacent to, facilities. Using the plant categories and site risk levels, injury thresholds (i.e., treatment priorities based on injury potential) for facilities can be established. This is described in detail in the KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants (shown in Appendix 3), and is shown in Table 12: Table 12: Injury (Treatment) Thresholds for the Noxious Weed and Invasive Plant Program Invasive Plant Category Site Risk Level Treatment Priority 1 1 Priority 1 1 2 Priority 1 1 3 Priority 1 32

2 1 Priority 2 2 2 Priority 3 2 3 Priority 4 3 1 Priority 2 3 2 Priority 3 3 3 Priority 4 4 1 Priority 3 4 2 Priority 4 4 3 Priority 5 Using the plant categories and site risk levels, injury thresholds (i.e., treatment priorities based on injury potential) can be established. This is described in detail in Appendix 3 (Pre-Treatment ROW Weed Monitoring Form). 3.7 Treatment Options for Noxious Weeds and Invasive Plants at Facilities [IPMR Section 58(2)(e)] IVMP involves the use of different treatment options to manage noxious weeds and invasive plants at facilities. In this context, herbicides may be required to target specific species of noxious weeds and invasive plants. The selection of a particular control technique will depend on: Timing; Site characteristics including adjacent land use, proximity to water sources, bodies of water, soil type and other environmentally sensitive features; Environmental sensitivities in surrounding areas; The noxious weed or invasive plant species being targeted; Safety, economic impacts and site accessibility; Species composition on the site and percentage cover; and, The consequences of not treating the noxious weeds or invasive plants observed. KMC may use, as appropriate, non-chemical (manual, mechanical and cultural) and chemical (i.e. herbicide) vegetation control methods/techniques within this IVMP for noxious weed and invasive plant control at facilities. These are listed in Table 13: Table 13: Vegetation Management Options, Methods and Techniques for Control of Noxious Weeds and Invasive Plants at Facilities Manual and Mechanical (Non-chemical) Geotextile fabric Hand pulling Mowing Weed trimming Cultural (Non-chemical) Irrigation and Fertilization Retaining existing ground cover Seeding Herbicide Applications (Chemical) Foliar Wick/wipe-on 33

3.7.1 Manual and Mechanical Control Methods [IPMR Section 58(2)(e)] Manual and mechanical methods of noxious weed and invasive plant control at facilities are effective and environmentally safe methods if timed correctly and precautions are taken to minimize soil disturbance and native vegetation loss. These methods are not practical for large areas, and alternative methods may have to be applied. The following information describes the currently available manual and mechanical options for noxious weed and invasive plant control at facilities. This list may not be wholly inclusive and does not prohibit the ability of KMC to utilize other generally accepted non-chemical methods of control. A description of the rationale and selection criteria, and the benefits and limitations of the manual and mechanical methods (as listed in Table 13) are shown in Tables 14: Table 14: Description of, Rationale and Selection Criteria for, and the Benefits and Limitations of Manual and Mechanical (Non-Chemical) Control Methods Description & Rationale/Selection Criteria Geotextile is a porous, polypropylene fabric that is generally placed below mulches, crushed rock or gravel. It is commonly used in landscaped areas such as flower or shrub beds. It works as a physical barrier preventing root growth of noxious weeds and invasive plants through the fabric. Hand Pulling is a viable control method only for certain established noxious weeds and invasive plants that can be easily uprooted and where the roots can be fully removed. It is effective if the number of weeds to be pulled is small and the site is a manageable size. When hand pulling is used, the exposed soil should be immediately covered with gravel. Mowing is the cutting of problem vegetation such as noxious weeds and invasive plants growing in the grassy areas within facilities. Vegetation can be mowed using equipment such as commercial Benefits and Limitations The advantages of using geotextile fabric are that their use has the potential to reduce the need for other control methods for noxious weed and invasive plant management. The limitations (disadvantages) of using geotextile fabric are that the initial placement of geotextile fabric can be labour intensive, and their use is limited for noxious weed and invasive plant control at facilities. The advantages of hand pulling are that it can be used In areas where there has been little or no vegetation management undertaken for an extended period of time. Hand pulling can be effective in reducing a large volume of vegetation to a manageable level. It may be one of the only alternatives for noxious weeds and invasive plants growing adjacent to bodies of water and other environmentally sensitive areas where herbicides cannot be used. The limitations (disadvantages) of hand pulling are that it is labour intensive, and that excessive hand pulling of noxious weeds and invasive plants tend to increase the amount of organic matter, which can encourage their establishment. The advantages of mowing include controlling noxious weeds and invasive plants before they go to seed, thus reducing the seed source available for dispersal to other areas of low vegetation tolerance within the facility. Mowing promotes aesthetics and is economical. The limitations (disadvantages) of mowing are that it is not 34

lawnmowers, garden tractors or industrial tractors. Weed-Trimming at the ground surface can be used in areas such as around perimeter fences, within landscaped areas, and at low priority sites to manage noxious weeds and invasive plants. suitable in areas that are rocky, on slopes, or where low-growing compatible species predominate. Mowing could stimulate vegetative growth of some species, causing a matting effect. Mowing does not eradicate weed species and is a temporary solution. There are some safety issues due to flying debris. Mowing generally is very labour intensive, as it has to be done several times at each location during a growing season. The advantages of weed trimming are that it helps to remove seed heads when done early in the season, and is convenient and economical. The use of weed trimmers is generally more suitable than mowers for use in areas that are rocky, have stumps, on slopes, where noxious weed and invasive plant species predominate, or are not accessible to lawnmowers or tractors. The limitations (disadvantages) weed trimming are that it does not remove roots, and has only limited effectiveness on species that reproduce from stem pieces. There are some safety risks due to flying debris. 3.7.2 Cultural Control Methods [IPMR Section 58(2)(e)] The cultural control methods that may be used to control noxious weeds and invasive plants within facilities include irrigation and fertilization, retaining existing ground cover, and seeding and planting grasses A description, rationale, selection criteria, and the benefits and limitations of seeding (revegetation) and the release of biological control agents are shown in Tables 15: Table 15: Description of, Rationale and Selection Criteria for, and the Benefits and Limitations of Cultural Control Methods Description & Rationale/Selection Criteria Irrigation and Fertilization refers to the fact that noxious weeds and invasive plants, like other plants, respond positively to increased water and nutrients. The key to using irrigation and fertilization as tools for effective noxious weed and invasive plant control is to first control the noxious weeds and invasive plants and then use irrigation and fertilization to promote the growth of competing vegetation. Retaining Existing Low Ground Cover involves leaving existing low-growing plant species undisturbed as much as Benefits/Limitations The advantages of using irrigation and fertilizing following the seeding of appropriate competitive forage species or erosion control mixes can result in reduced levels of noxious weed and invasive plant establishment by increasing competition. The only limitation (disadvantage) of irrigation and fertilization is that in order to effective, the noxious weed and invasive plants must have been eliminated from a site prior to the use of irrigation and fertilization. The advantages of retaining existing low ground vegetative cover will generally result in physical controls and chemical controls only being applied to 35

possible during the construction of new facilities, or when mechanically removing problem tall-growing vegetation. During the construction of new facilities, or when mechanically removing problem tall growing vegetation, the existing lowgrowing plant species will be left undisturbed as much as possible. Seeding and Planting Grasses involves re-vegetating bare/disturbed ground and landscaped areas in facilities with a suitable mixture of species compatible to the surrounding land capability and use. This method involves the planting of certified grass seed that will reduce the risk of noxious weed and invasive plant establishment. targeted noxious weed and invasive plant species in these areas. Existing groundcover allows the competitive plants to out-compete the noxious weed and invasive plant species that may invade from adjacent areas. The only limitation (disadvantage) on retaining existing low ground cover is the initial cost of establishing the lowgrowing competitive vegetation. The advantages of seeding and planting grasses are that it prevents erosion, inhibits weed establishment and growth, and promotes aesthetics. Maintaining grasses at a level of 7.5 cm, combined with proper fertilization, provides a dense growth of grass that will inhibit the introduction and growth of weeds. The limitations (disadvantages) of seeding and planting grasses are that it requires continued maintenance (i.e. mowing), does not provide a stable plant community because unwanted species may invade, and the sustained promotion of grasses as a monoculture in forested areas may pose a fire hazard if there are insufficient numbers of grazing animals. 3.7.3 Chemical Control (Herbicides) [IPMR Section 58(3)(c)] The selective and limited use of herbicides is an important part of the KMC IPM program at facilities to control noxious weeds and invasive plants. An IPM program that combines the manual/mechanical/cultural methods discussed earlier with the site specific use of herbicides is often the only effective way to establish a stable, low-growing plant community. Manual/mechanical/cultural control methods used alone will not keep noxious weeds and invasive plants below injury thresholds over the long-term due to re-sprouting. In addition, herbicides may be required to target specific of noxious weeds and invasive plants within facilities. Herbicides Proposed for Use to Control Noxious Weeds and Invasive Plants at Facilities Herbicide identification, use areas, properties and use patterns, application methods and techniques (including rationale/selection criteria, benefits and limitations for each herbicide), and equipment for all herbicides proposed for use under this IVMP for noxious weed and invasive plant control at KMC facilities will be further discussed in section 4.7 of this IVMP. 3.8 Treatment Selection Criteria [IPMR Section 58(2)(e)] 36

Prior to selecting a treatment method (chemical or non-chemical) for a noxious weed or invasive plant infestation at facilities, the following considerations will be taken into account, as appropriate/applicable: Recording the site location and site characteristics, and establishing treatment area boundaries (See Section 5.5 for details); Documenting if the infestation is within a community watershed, and, if so, what strategies would be required for its protection with the treatment method chosen (See Section 5.1 for details); Documenting if the infestation is within 30 meters of domestic or agricultural water sources, and, if so, what strategies would be required for their protection with the treatment method chosen (See Section 5.2 for details); Documenting if the infestation is adjacent to fish and wildlife, riparian areas or wildlife habitat, and, if so, what strategies would be required for their protection with the treatment method chosen (See Section 5.3 for details); Documenting if the infestation is adjacent to areas where food for human consumption is grown or found, and, if so, what strategies would be required for their protection with the treatment method chosen (See Section 5.4 for details); Documenting if there are human activities associated with, or adjacent to, the site of the infestation, and, if so, what strategies would be required for their protection with the treatment method chosen; and, Ensuring that all herbicide use is consistent with the commitments made in this IVMP and then applicable sections of the IPMR. 3.9 Evaluation of Herbicide Treatments (Post-Treatment Monitoring) [IPMR Section 58(2)(f)] Post-treatment monitoring will be conducted at least two times during the growing season at all facilities to which herbicides have been applied, or as frequent as KMC personnel or vegetation specialists determines inspections to be warranted based on available and effective strategies until infestations have been reduced to below threshold levels. All inspection results will be documented in the KMC Post-Treatment(s) Monitoring Form shown in Appendix 4, and will include the following information: Date of inspection/inspector; Description and location of site inspected; Date of herbicide(s) and/or non-chemical treatment(s); Herbicide(s) applied, application rate, and area treated; Licensed contractor and certified applicator in attendance; Post-treatment inspection observations, including weather conditions during treatments, confirmation of Treatment Notice posting, and visual signs of off-target damage to adjacent vegetation. Photographs will be taken at each facility inspected and included in the monitoring form; Environmental features requiring protection and environmental protection measures taken; Treatment efficacy, and whether site objectives were achieved; Comments and recommendations; and, Compliance with the IPMR commitments made in this IVMP; 37

4.0 OPERATIONAL INFORMATION The operational information included in this section includes the following procedures for all herbicides proposed for use under this IVMP for both problem vegetation and noxious weed and invasive plant control at KMC facilities: The operational information included in this section includes: Qualifications and responsibilities of persons applying herbicides; Procedures for safely transporting herbicides; Procedures for safely storing herbicides; Procedures for safely mixing, loading and applying herbicides; Procedures for the safe disposal of empty herbicide containers and unused herbicides; Procedures for responding to herbicide spills; Herbicide identification, use areas, properties and use patterns, and application methods/techniques (including rationale/selection criteria, benefits and limitations for each herbicide) for all herbicides proposed for use under this IVMP; and, Equipment, methods and techniques for herbicide applications. The transportation, storage, handling, application and disposal of pesticides are governed by federal and provincial legislation. All outside contractors working with pesticides on property owned or controlled by KMC will follow safe handling practices including workplace requirements for Workplace Hazardous Materials Information System (WHMIS), labeling and worker education. The required practices governing contractors and their workers are detailed in: WorkSafeBC s (1998) Occupational Health and Safety Regulation - BC Regulation 296/97 as amended by BC Regulation 185/99-Sections 6.70 to 6.97 including Section 6.77 Mixing, Loading and Applying Pesticides Qualifications (Amended by BC Regulation 188/2011, effective February 1, 2012) B.C Ministry of Environment (2011) Canadian Pesticide Education Program Applicator Core Manual, British Columbia Edition; and, WorkSafeBC s (2009) Standard Practices for Pesticide Applicators. 4.1 Qualifications and Responsibilities of Persons Applying Herbicides All pesticide applications will be conducted or supervised by a person who holds a Pesticide Applicator Certificate endorsed for the class of pesticide and the pesticide use required for herbicide applications under this IVMP. Any individual or company (i.e., a contractor) that provides a service to KMC by applying commercial or industrial herbicides for invasive plant or problem vegetation control at KMC facilities must have a valid BC Pesticide User Licence. The responsibilities of the Certified Pesticide Applicator are to: Be in continuous attendance at the site; Have available proof of certification; Supervise no more than 4 uncertified assistants at one time [IPMR Section 46(31(a)(ii)]; Maintain continuous contact, auditory and/or visual, with the uncertified assistants; 38

Be within 500 meters of persons being supervised; and, Comply with the standards contained in Division 7 of the IPMR. 4.2 Procedures for Safely Transporting Herbicides [IPMR Section 58(3)(a)(i)] Personnel shall follow these procedures for safely transporting herbicides: Ensure that herbicides are carried in a compartment that is secured against spillage and unauthorized removal. The compartment shall be separate from food and drinking water, safety gear, spill containment equipment and people; Inspect all herbicide containers for defects prior to transporting. Keep herbicides in their original containers and with original labels. If original labels are not available, the herbicides shall be placed in appropriate containers that have the trade name, active ingredient concentration and pesticide registration number affixed to the outside of the container; Ensure that the vehicle is equipped with a first aid kit, fire extinguisher, spill contingency plan and kit, and that the vehicle operator has been trained on how to handle spills; Ensure that all documents and placards are carried in, or placed on, transport vehicles if required under the Transport of Dangerous Goods Act, R.S.B.C 1996, c. 458, and regulations, the IPMA or the IPMR; and, Read and understand the herbicide labels and the product Material Safety Data Sheet (MSDS) for all herbicides being transported. 4.3 Procedures for Safely Storing Herbicides [IPMR Section 58(3)(a)(ii)] Personnel shall follow these procedures for safely storing herbicides: Ensure that herbicides are stored in accordance with the IPMA, IPMR and the Workers Compensation Board document Standard Practices for Pesticide Applicators (2009); Keep herbicides in their original containers and with original packaging. If original packaging is not available, the herbicides shall be placed in appropriate containers that have the trade name, active ingredient concentration and pesticide registration number affixed to the outside of the container; Ensure that storage facilities are locked when left unattended, ventilated to the outside atmosphere, are entered only by persons authorized to do so, and that there is a placard affixed and maintained on the outside of each door leading into the storage area bearing, in block letters that are clearly visible, the words WARNING CHEMICAL STORAGE AUTHORIZED PERSONS ONLY ; and, Keep storage facilities separate from work and living areas, and away from food, flammable materials, bodies of water and water sources. 4.4 Procedures for Safely Mixing, Loading and Applying Herbicides [IPMR Section 58(3)(a)(iii)] 39

Personnel shall follow these procedures for safely mixing, loading and applying herbicides: Ensure that all mixing, loading and application of herbicides is carried out by Certified Pesticide Applicators, and that all manufacturer s recommendations, as specified on the herbicide labels, are adhered to, Ensure that all mixing, loading and application of herbicides shall be undertaken in a safe manner. All mixing and loading shall be undertaken only in areas at least 15 meters from, and selected to prevent, any spilled herbicides from entering pesticide-free zones, no treatment zones, bodies of water, fish or wildlife habitat, water sources, or other environmentally sensitive areas; Ensure that containers used to mix, prepare or apply herbicides are not washed or submerged in any body of water; Ensure that eye wash station(s), protective clothing, safety spill kits, spill response plans, a copy of this integrated vegetation management plan, each herbicide product s MSDS, emergency telephone numbers and first aid supplies are present and available at or near the treatment site; and To follow all directions and restrictions on herbicide product labels, including adhering to the recommended re-entry times to treated areas unless personal protective equipment is worn. 4.5 Procedures for the Safe Disposal of Empty Herbicide Containers and Unused Herbicides [IPMR Section 58(3)(a)(iv)] Personnel shall follow these procedures for safely disposing of empty herbicide containers and unused herbicides: Ensure that all herbicide waste is disposed of in a manner consistent with the requirements of the Environmental Management Act, S.B.C. 2003, c. 53 and the Hazardous Waste Regulation B.C. Reg. 63/88, as appropriate; Ensure that empty herbicide containers are returned to the herbicide distributor as part of their recycling program; or triple rinsed or pressure rinsed, altered so that they cannot be reused, and disposed of in a permitted sanitary landfill or other approved disposal site; and Ensure that all leftover herbicide mix is stored for future use in a manner consistent with the requirements specified in Section 3.3 above. 4.6 Procedures for Responding to Herbicide Spills [IPMR Section 58(3)(a)(v)] Contractors that work under this IVMP must have their own spill response plan that incorporates the requirements specified below: Spill treatment equipment shall be present or near storage (including mobile storage), mixing and loading sites and shall include: personal protective equipment, absorbent material, neutralizing material, a long handled broom, shovel, and a waste-receiving container with lid; 40

A copy of the spill response plan shall be at or near each work site, and all personnel working on the project shall be familiar with its contents; All personnel shall be protected from herbicide contamination by wearing appropriate protective clothing and safety gear; Any person exposed to a herbicide shall be moved away from the place of the spill; First aid shall be administered, if required; The source of the spill shall be stopped; The spilled material shall be stopped from spreading by creating a dam or ridge; The project supervisor shall ensure that operations cease until the spill is contained and the source is repaired; Absorbent material shall be spread over the spill, if applicable, to absorb any liquid; The absorbent material shall be collected in garbage bags or containers with contents clearly marked; Contaminated soil or other material shall be removed from the spill site and placed in garbage bags or containers; The person responsible for the project shall contact KMC for shipping instructions and disposal requirements; When more than 5 liters or 5 kg of herbicide are spilled, the person responsible for the project shall immediately report to the BC Provincial Emergency Program by telephoning 1-800-663-3456 or, where that is not practical, to the local police or nearest detachment of the RCMP; and, An approved representative of KMC shall be notified of the details related to the spill as soon as practical by the Contractor project supervisor. 4.7 Herbicide Identification, Use Areas, Properties and Use Patterns for All Herbicides Proposed for Use [IPMR Section 58(3)(c)] 4.7.1 Herbicide Identification and Use Areas As was discussed in Sections 2.8.2 (Chemical Control Options for Problem Vegetation at Facilities) and 3.7.3 (Chemical Control Options for Noxious Weeds and Invasive Plants at Facilities), the herbicides proposed for use in this IVMP is summarized in Table 16: Table 16: Identification of Herbicide Active Ingredients Proposed for Use in Facilities and Their Use Areas Active Ingredient aminocyclopyrachlor aminopyralid chlorsulfuron clopyralid dicamba diflufenzopyr diuron flumioxazin fluroxypyr Use Area Problem Vegetation Problem Vegetation and Noxious Weed/Invasive Plant Problem Vegetation and Noxious Weed/Invasive Plant Noxious Weed/Invasive Plant Problem Vegetation and Noxious Weed/Invasive Plant Problem Vegetation and Noxious Weed/Invasive Plant Problem Vegetation Problem Vegetation Problem Vegetation and Noxious Weed/Invasive Plant 41

glyphosate imazapyr indaziflam MCPA (dimethylamine salt) mecoprop-p (dimethylamine salt) metsulfuron-methyl picloram triclopyr 2,4-D Amine Hasten Siloxylated polyether Problem Vegetation and Noxious Weed/Invasive Plant Problem Vegetation Problem Vegetation Noxious Weed/Invasive Plant Noxious Weed/Invasive Plant Noxious Weed/Invasive Plant Noxious Weed/Invasive Plant Problem Vegetation and Noxious Weed/Invasive Plant Problem Vegetation and Noxious Weed/Invasive Plant Adjuvant Adjuvant *Due to the proposed 5 year duration of the IVMP, it is not possible to precisely forecast with certainty which herbicide active ingredients will or will not be used. The above list includes all possible active ingredients that may be used within the term of the IVMP. Many of the abovelisted active ingredients are sold by several chemical manufacturers under a variety of Trade Names. It is not practical to list all of the potential Trade Names for the active ingredients that may be used under this IVMP in this document. KMC reserves the right to utilize any and all of the available products (i.e. Trade Names) for the above listed active ingredients provided that they are registered for the intended purpose under the Federal Pest Control Products Act. 4.7.2 Properties of Herbicide Active Ingredients The properties of the herbicide active ingredients proposed for use are shown in Table 17. The properties listed include soil residual activity, mode of action, selectivity and where and when applied: Table 17: Properties of Herbicide Active Ingredients Proposed for Use Active Ingredient Residual Activity* Mode of Action Selectivity ** Where and When Applied *** aminocyclopyrachlor moderate translocation selective foliage; post-emergent aminopyralid moderate translocation non-selective foliage; post-emergent chlorsulfuron moderate contact selective foliage; soil, postemergent clopyralid high translocation selective foliage; soil, postemergent dicamba low translocation selective foliage & cut surface; post-emergent diflufenzopyr low translocation non-selective foliage; post-emergent diuron moderate translocation non-selective soil; pre-emergent flumioxazin moderate contact non-selective soil; pre-emergent fluroxypyr low translocation non-selective foliage; post-emergent glyphosate low translocation non-selective foliage & cut surface; post-emergent imazapyr moderate translocation non-selective foliage & soil; pre and post-emergent 42

indaziflam moderate translocation non-selective soil; pre-emergent MCPA (dimethylamine low translocation selective foliage; post-emergent salt) mecoprop-p low translocation selective foliage; post-emergent (dimethylamine salt) metsulfuron-methyl moderate translocation non-selective foliage, post-emergent picloram high translocation selective foliage, post-emergent triclopyr low translocation selective foliage & cut surface; post-emergent 2,4-D Amine low translocation selective foliage, post-emergent Hasten low adjuvant Siloxylated polyether low silicone surfactant (adjuvant) * LOW generally refers to residual soil activity of up to 40 days, MODERATE for residual soil activity of up to one year and HIGH for residual soil activity of greater than one year. ** Herbicides that control all vegetation are termed non-selective, while those that control certain types of vegetation (e.g., only grasses or only broadleaf) are termed selective. *** Post emergent refers to treatments made after the vegetation has emerged through soil surfaces and pre-emergent refers to treatments before the vegetation has emerged through the soil surface. 4.7.3 Use Patterns of Herbicide Active Ingredients [IPMR Section 58(3)(c)] Table 18 summarizes the use patterns of the herbicides being proposed for use within this IVMP: Table 18: Use Patterns of Herbicide Active Ingredients Proposed for Use Active Ingredient aminocyclopyrachlor aminopyralid Use Pattern Is combined with the herbicide active ingredient metsulfuron-methyl to form the product Navius VM herbicide. Navius is a dispersible granule mixed in water and applied as a selective, foliar spray for control of undesirable brush and woody species in non-crop areas. It is quickly taken up by the leaves, stems and roots and translocated throughout the plant. Visible effects (bending and twisting of stems and leaves) may be seen on plants within a few hours of application. Is a selective, residual herbicide, giving season-long control when used at label application rates. It is useful for spot treatment control or suppression of many noxious weed and invasive plant species (e.g. biennial and perennial thistles, knapweeds, yellow starthistle, scentless chamomile and common tansy), woody plants, annual and perennial broadleaf weeds. It is effective only on actively growing plants. It is absorbed through leaves and roots, and translocates throughout the plant. It interrupts cell division and 43

chlorsulfuron clopyralid dicamba diflufenzopyr diuron causes the plants to die. It is safe to desirable grasses, and its systemic and residual properties effectively controls invasive plants at multiple growth stages. Is useful for the control of hard to manage annual and perennial broadleaf vegetation by both foliar and root uptake. It may be used to spot treat horsetail, as well as other established species not controlled by other herbicides within facilities. Under this IVMP, chlorsulfuron will not be used as a soil-applied residual herbicide. It is effective at very low application rates. It will not be applied near trees or other desirable plants, in areas where their roots may extend, or in locations where it may be moved or washed into contact with the roots. It will not be applied during extremely rainy periods, when soils have been heavily saturated, onto ground which slopes to desirable plants. Is a selective, residual herbicide that is useful for the spot treatment control of many species of broadleaf noxious weeds and invasive plants. It is effective only on actively growing plants. Its use is preferable to that of picloram for the control of Canada thistle, perennial sowthistle, wild buckwheat, common groundsel, common ragweed, sheep sorrel, oxeye daisy, and scentless chamomile, in areas where herbicides of long residual soil activity should not be used. It does not affect many woody species such as trees and shrubs. It can be used in areas where the over story of trees and shrubs are present at the infestation site and there is a need to minimize or prevent damage to these non-target plants. For perennial weeds, it will control the initial top growth and inhibit regrowth during the season of application. Is used for the spot treatment of young, actively growing broadleaf vegetation and brush species, including many species of noxious weeds and invasive plants (e.g. Canada thistle, perennial sow thistle, leafy spurge, common tansy, field bindweed, curled dock, diffuse knapweed, sheep sorrel and velvetleaf). It will control many broadleaf herbaceous species that cannot be effectively treated using physical controls or glyphosate applications. It can be safely mixed with other herbicides to broaden the number of target species controlled. Because it is a selective herbicide, it is useful in areas where grasses are to be retained on the site. It has been shown to control Is the first active ingredient from a chemical class called semicarbazones. It is low toxicity to humans, birds, aquatic organisms, mammals and bees. It has low residual properties. It causes hormones in plants to become concentrated in the growth regions. When applied with dicamba (Overdrive), it focuses dicamba s translocation to the high growth regions, where it delivers effective weed control at reduced dicamba rates and across a wider range of weed species. It is applied post-emergent to the foliage of target plants. Is used to control many annual and perennial grasses and herbaceous vegetation at facilities. When applied to the soil, it is useful in preventing the germination and growth of seedling 44

flumioxazin fluroxypyr glyphosate imazapyr vegetation. As it requires moisture (minimum 12 mm) to move it into the root zone, application timing is important in drier areas. As a result of the moisture requirement for activation, the effects on vegetation are slow to appear and will not become apparent until the diuron has been absorbed into the plant and leaves. At the highest label rates, it is a residual, non-selective herbicide. At lower label rates, it is a selective, pre-emergent herbicide for the control of seedling broadleaf vegetation and grasses. It is a soil applied, residual herbicide that requires moisture to move it into the root zones of the target vegetation. The best control with this herbicide is when it is applied to the soil shortly before the vegetation begins to grow. Is used for non-selective, residual, pre-emergence control of selected grasses and broadleaf weeds on bare ground, non-crop land. It is most effective when applied to clean, weed-free soil surfaces. The length of residual control will decrease as temperature and precipitation increases, and on soils of high organic matter and/or clay content. Is a post-emergence, synthetic herbicide that internally disrupts weed growth resulting in target plant death. It is effective on annual and perennial weeds and woody brush. Fluroxypyr is systemic and rapidly absorbed by foliage of growing plants. Plant growth is disrupted by the deregulation of the cellular growth process following binding of fluroxypyr to plant cell hormone receptor sites. It also interferes with the plant s ability to metabolize nitrogen and produce enzymes. Is a non-residual herbicide used to control a very large number of species of noxious weeds and invasive plants. It is only effective for treating plants that have germinated, emerged above the soil, and are actively growing at the time of spraying. It is most useful in areas where low soil residual is required because of the close proximity of wells, water bodies and other environmentally sensitive features. It is deactivated quickly in the soil, where it moves very little from the point of application. Glyphosate is used to control a very large number of herbaceous broadleaf and grass species and woody vegetation. It can be applied to cut vegetation or young seedlings which emerge following trimming or hand pulling to further reduce site organic matter, or where physical control methods are not effectively controlling vegetation. Glyphosate can also be used for selectively treating deciduous tree species growing outside of facility fences, perimeter areas or along access roads, particularly against those species that re-sprout following cutting. Imazapyr is used to control broadleaf vegetation, annual and perennial grass species and woody vegetation (especially maple). It works by preventing germination of seeds. It is readily absorbed through foliage and roots and moves rapidly throughout the plant, where it breaks down tissue. It is particularly useful in controlling vegetation that has not been effectively managed using a combination of physical controls and glyphosate application. Treated plants stop growing soon after spray application. 45

indaziflam MCPA (dimethylamine salt) mecoprop-p (dimethylamine salt) metsulfuron-methyl picloram Is a pre-emergent, residual herbicide for the control of annual grasses and broadleaf weeds in non-residential, non-crop areas such as along fence rows, within utilities industrial sites. Indaziflam controls weeds by reducing the emergence of seedlings through inhibition of cellulose biosynthesis (CB Inhibitor). Necrosis or yellowing may also be observed if the herbicide is applied to herbaceous tissue such as leaves and green stems of susceptible plants. If applied alone, it will not control weeds that are already emerged. If weeds have emerged, a foliar active post-emergent herbicide must be added. Treatments are most effective in controlling weeds when adequate moisture is present and the application is followed by rain prior to weed seed germination. Weed seeds and seedlings must come into contact with this herbicide prior to emergence to be controlled. If sufficient moisture is present, some weeds may germinate and emerge from below the treated layer. Excessive plant debris present on the soil surface at time of application may prevent uniform product distribution reaching the soil and reduce weed control. Performance may be improved by removing excessive debris prior to product application. Is a selective, foliar applied broadleaf herbicide used for the control of numerous species of noxious weeds and invasive plants in noncrop and industrial areas. It is absorbed through the leaves or roots and is readily translocated in the plant. At recommended rates, MCPA persistence in the soil is up to one month in most growing conditions and up to 6 months in drier climates. Is a selective, non-residual, translocated herbicide that interferes with growth regulation in noxious weed and invasive plant species. Is most effective when the target plant is growing rapidly, and is more actively taken up by the foliage than by the roots. Average persistence of mecoprop-p in soil is one to four weeks. Persistence is longer in cold, dry soils. Persistence in soil may prove injurious to subsequent crops of sensitive plants. Application equipment must be thoroughly cleaned with special materials before applying other pesticides to sensitive crops. Is a translocated, non-selective herbicide of moderate persistence used for noxious weed and invasive plant control in non-crop areas. It is applied as a foliar spray. It rapidly inhibits the growth of susceptible plants, but typical symptoms (discolouration) may not be noticeable for several weeks after application, depending on growing conditions and plant susceptibility. Warm, moist conditions following application promote its activity while dry, cold conditions may reduce or delay activity. Invasive plants hardened off by cold weather or drought stress may not be controlled. Degree of control and duration of effect are dependent on the application rate used, sensitivity and size of the target species, as well as soil moisture and soil temperature. Noxious weeds and invasive plants controlled include common tansy, kochia, scentless chamomile, Canada thistle and sow thistle. Is a selective, residual, systemic herbicide used for the control many species of noxious weeds and invasive plants. Grasses are quite 46

triclopyr 2,4-D amine Hasten Siloxylated polyether tolerant. It can remain in the soil for several years and continue to control susceptible weeds. Due to its' persistence in the soil, care must be taken to avoid areas where soil may be moved or where there are shallow aquifers or domestic water intakes. The mode of action and persistence allow for a broader application window. It is absorbed by foliage and roots and translocated. It acts as a growth regulator, somewhat more active than, but similar to 2,4-D. It is broken down in clear water by sunlight and is degraded in warm, moist soil having good organic matter content. Some leaching may occur in sandy soils. Is effective in controlling established perennial vegetation and brush species. Triclopyr may also be used to selectively control trees that are encroaching on perimeter fences or alongside access roads. On trees, it is applied as a basal bark treatment. It is particularly effective in controlling trees that commonly re-sprout following cutting. Triclopyr is absorbed by both leaves and roots and readily moves throughout the plant. For control of birch and aspen, it is more effective than glyphosate. Is a selective, non-residual, translocated herbicide that interferes with growth regulation in invasive plant species. It is most effective when the target plant is growing rapidly, and is more actively taken up by the foliage than by the roots. The average persistence of 2,4- D in soil is one to four weeks. Persistence is longer in cold, dry soils. Persistence in the soil may prove injurious to subsequent crops of sensitive plants. Application equipment must be thoroughly cleaned with special materials before applying other pesticides to sensitive crops. Adjuvant* Surfactant* 4.7.4 Use of Surfactants or Adjuvants Adjuvants and surfactants are chemicals or agents that are sometimes added to herbicide spray mix to allow easier mixing, and to assist in the spreading of the herbicide spray mix and the wetting of, and adherence to, the surface of the plants being treated. This has been shown to decrease the possibility of drift (the movement of the applied material away from the intended target to adjacent areas by wind). Some adjuvants and surfactants are chemicals or agents that are sometimes added to surfactants may also be used to adjust the ph of the herbicide spray mix. Spray mixes that are highly or mildly alkaline (i.e. ph greater than 7) have been shown to break down (degrade) or hydrolyze more rapidly, reducing the effectiveness of the herbicide being applied. If required, surfactant/adjuvant products may be added to the herbicide active ingredients proposed for use under this IVMP. 4.8 Herbicide Application Equipment, Methods and Techniques [IPMR Section 58(3)(c)] 47

4.8.1 Herbicide Application Equipment Depending on the type of herbicide treatment being carried out, the application equipment that may be used within this IVMP include backpack, power hose and nozzle, wick/wipe-on applicator and boom sprayer (generally mounted on an all-terrain vehicle). Definitions: Backpack - a portable, manually operated, low pressure container with a nozzle for applying herbicides and a positive shut-off system. A backpack sprayer will be used to apply herbicides to the cut surface of stumps of deciduous vegetation, to treat the foliage of target plants (problem vegetation and noxious weeds and invasive plants), to apply herbicides to basal bark area of individual deciduous stems, and for the application of herbicides to the soil. Power Hose and Nozzle - A power hose and nozzle (handgun) is a hand-held spray gun and hose attached to a portable tank filled with herbicide solution, usually with a power driven pump to provide pressure to the herbicide solution in the hose. Handguns are generally used at sites where large areas within facilities have to be treated with herbicides. Wick/Wipe-On - absorbent pads, wicks or rope attached to a long-handled applicator stick used to selectively apply herbicides to foliage or to the cut surface of deciduous stumps. Boom Sprayer are designed to distribute low to moderate herbicides application rates evenly over a larger areas. They are generally mounted on an ATV with a power-driven pump, and may be used for the application of herbicides within facilities and along their perimeter fences. 4.8.2 Herbicide Application Methods/Techniques [IPMR Section 58(3)(C)] The herbicide application methods/techniques proposed for use under this IVMP include foliar, soil, basal bark, cut surface and wick/wipe-on. A description, rationale, selection criteria, and the benefits and limitations of the above listed chemical (herbicide) control methods/techniques are shown in Table 19: Table 19: Description of, Rationale and Selection Criteria for, and Benefits and Limitations of Chemical (Herbicide) Control Methods/Techniques Description & Rationale/Selection Criteria Foliar is where a manually operated backpack sprayer, power hose and nozzle or boom sprayer that is used to apply herbicides to the foliage of actively growing target plants. This method/technique may be used to apply all of the active ingredients proposed for use except of chlorsulfuron, clopyralid, diuron, Benefits and Limitations The advantages of foliar applications are that they can be carried out at any time of the year, provided the target plants are actively growing. The limitations (disadvantages) of foliar applications are they are susceptible to drift, and caution must be exercised around desirable plants and environmentally sensitive areas. If non-selective herbicides are being applied, they will control both the target vegetation and desirable plants that are growing among them. 48

flumioxazin and indaziflam. Soil is where a manually operated backpack sprayer, power hose and nozzle or boom sprayer that is used to apply herbicides to the soil, generally for pre-emergent weed control. This method/technique may be used to apply the active ingredients chlorsulfuron, clopyralid, diuron, flumioxazin and indaziflam. Basal bark is technique involves applying the active ingredients dicamba, glyphosate and triclopyr to the bark of deciduous trees from the root collar to a point above the ground, where it then penetrates into the cambium layer and diffuses throughout the tree. It also travels to the roots and prevents re-sprouting. Trees may take 3 years to be killed with basal bark applications. Cut surface is where the problem deciduous vegetation is cut as low to the ground as possible and herbicide is applied to the cut surface of the stump to limit re-sprouting. The active ingredients dicamba, glyphosate and triclopyr may be applied using this method/technique. Wick/wipe-on is where a wick soaked with the herbicide is wiped or dragged over the foliage of the target vegetation. This technique will generally be used where cut stumps have re-sprouted, or for treating small patches of vegetation located within sensitive areas within facilities. The advantages of soil applications are they can be used for vegetation control within most facilities where long-term control of all vegetation is the objective. They are effective in preventing seed germination of some broadleaf vegetation, annual and perennial grasses when applied to the soil. The limitations (disadvantages) of soil applications are because they herbicides with moderate or high residual activity, care must be exercised in their use within facilities if used in areas subject to heavy rainfall or snow, as the herbicides may be washed or move off-site. The advantages of basal bark applications are that because they are restricted to the basal areas of the bark, there is generally no herbicide drift, resulting in no impact to adjacent environmentally sensitive areas. They pose little risk of herbicide exposure to workers or the general public. The selective control of the tallgrowing deciduous trees generally results in the growth of low growing forage plants for wildlife. The limitation (disadvantages) is that this method/technique is not effective in wet weather. The advantages are this is a preferable technique in highly visible areas or in areas. There is generally no herbicide drift, resulting in minimal impact to adjacent environmentally sensitive areas. They pose nlittle risk of herbicide exposure to workers or the general public. The selective control of the target trees generally results in the growth of low-growing forage plants for wildlife. The limitations (disadvantages) of cut surface applications are that they are not effective in controlling deciduous vegetation that re-sprouts through root suckering. If treatment is not undertaken immediately following manual/mechanical treatment, this technique may not be successful. The advantages are this application technique virtually eliminates drift, and is useful for the safe and effective treatment of individual plans or stems located in areas of desirable vegetation. The limitations (disadvantages) are this technique is labour intensive and is only practical to use for small treatment areas or for a small number of individual plants. 49

5.0 ENVIRONMENTAL PROTECTION STRATEGIES AND PROCEDURES All vegetation management activities, both chemical and non-chemical, proposed for use under this IVMP will incorporate: Strategies to protect community watersheds, and other domestic and agricultural water sources; Strategies to protect fish and wildlife, riparian areas, and wildlife habitat; Strategies to prevent herbicide contamination of food intended for human consumption; Pre-treatment inspection procedures for identifying treatment area boundaries; Procedures for maintaining and calibrating herbicide application equipment; and Procedures for monitoring weather conditions and strategies for modifying herbicide application methods for different weather conditions. In this IVMP, all pesticide-free zones (PFZs) and no treatment zones (NTZs) will comply with the standards contained in Division 7 of the BC IPMR. Definitions Pesticide-free zone (PFZ) - an area of land that must not be treated with pesticides, and must be protected from pesticides moving into it. PFZs are measured by the horizontal distance from the high water mark. PFZs will be identified, marked/flagged prior to any herbicide application. No-treatment zone (NTZ) - an area of land that must not be treated with pesticides. NTZs will be identified, marked/flagged prior to any herbicide application. Body of water - any watercourse or body of water, such as a stream, river, wetland, or lake, but not including a human-made, self-contained body of water or structure of water. Stream - a watercourse that contains water on a permanent or seasonal basis, is scoured by water, or contains observable deposits of mineral alluvium, and which has a continuous channel bed that is 100 m or more in length, or flows directly into a fish stream or a fishbearing lake or wetland, or a licensed waterworks. Wetland - a swamp, marsh, bog, or other similar area that supports natural vegetation, and which is distinct from adjacent upland areas. 5.1 Strategies to Protect Community Watersheds [IPMR Section 58(3)(b)(i)] The Ministry of Environment s document B.C. Integrated Pest Management Regulations for Forestry, Noxious Weed and Industrial Managers (March 2012) provides a summary of requirements and explanatory notes for Pest Management Plan Development including strategies to protect Community Watersheds. Section 8 of the Government Actions Regulation (Forest and Range Practices Act) enables the Minister responsible for the Land Act (MFLNRO) to designate as a community watershed, all or part of the drainage area that is upslope of the lowest point from which water is diverted for human consumption by a licensed waterworks. This can occur if the Minister is satisfied that to protect the water that is diverted for human consumption the area requires special management in order to: 50

a. conserve the quality, quantity and timing of water flow, or b. to prevent cumulative hydrological effects that would have a material adverse effect on the water. There are currently 467 approved Community Watersheds. Of the approved Community Watersheds, 429 were grand parented under the Forest Practices Code of BC Act. These watersheds met the following criteria on or before June 15, 1995: water use for human consumption is licensed under the Water Act for a waterworks or domestic water users' community purpose; the water intake is on a stream; and the drainage area of the entire watershed upstream of the water intake does not exceed 500 square kilometres. Interim Guidelines and Procedures on the Designation, Amendment and Cancellation of Community Watersheds under the Forest and Range Practices Act were developed in 2008. http://www.env.gov.bc.ca/wsd/plan_protect_sustain/comm_watersheds/cabinet/community_wat ershed_guidelines-20008.pdf. This document does not include updated standards, practices or measures for pesticide management. For Water Stewardship for Community Watersheds, the Ministry of Environment maintains reference to the Community Watersheds Guidebook. The purpose of this Guidebook is to explain resource development practices that are intended to prevent long-term change to background water quality, quantity, and timing of flow. The guidelines presented in the Community Watersheds Guidebook recognize water quality, quantity and timing of flow as the principal values in community watersheds. This includes a section on guidelines for Pesticide Management. KMC recognizes that this Guidebook is not referenced in the Forest and Range Practice Act; however, given the objectives of this Guidebook it is appropriate for KMC to base its strategies for protection of community watersheds on this provincial document. KMC will identify the locations of community watersheds within using provincial databases, including the BC Water Resource Atlas and imapbc. Through continued consultation, KMC will review these locations with respective stakeholders confirm that these correspond with areas that require protection. Through its pre-treatment monitoring program, KMC will determine whether any invasive/noxious weed species are present within these identified watersheds and whether control measures are required. In this circumstance, KMC will refer to the provincial well registry to determine the location of licensed Points of Diversion. KMC will also consult with necessary stakeholders (i.e. First Nations communities) to determine the location of any water intakes. The following no-treatment zones with respect to community watershed boundaries and water intakes are to be adhered to with treatment of noxious/invasive weeds. In the event that management of invasive/noxious species is prescribed within no-treatment zones, KMC will work collaboratively with stakeholders to review alternative treatment options (i.e. manual or mechanical methods). Herbicides shall not be stored within a community watershed for more than 24 hours prior to their use, and removed from the community watershed within 7 days of use, unless they are stored in a permanent structure; 51

A 10 meter pesticide-free zone (PFZ) shall be maintained from the point of herbicide application and all bodies of water within the community watershed; Do not apply pesticides within 100 m upslope of a community water supply water intake; Do not apply pesticides within 30 m downslope of a community water supply water intake; All PFZs shall be measured and marked/flagged prior to herbicide use; and Herbicide use shall be discontinued if herbicide residues or herbicide breakdown products directly resulting from KMC herbicide applications are detected at a community watershed water intake, and further use shall not be undertaken until the BC Ministry of Health Services, Medical Health Officer, has been satisfied that all required measures have been implemented to preserve water quality. 5.2 Strategies to Protect Domestic and Agricultural Water Sources and Bodies of Water [IPMR Section 58(3)(b)(i)] KMC shall ensure that, prior to herbicide use, strategies are developed and implemented that identify and protect domestic and agricultural water sources and bodies of water. Table 20 describes the minimum measures that shall be implemented. The PFZ s and NTZ s in this table are consistent with the standards as specified in Division 7 of the IPMR: Table 20: Minimum Water Protection Measures for Herbicide Applications IPMR Section Permitted Applications NTZ/PFZ Exception 71(3) Around a water supply intake or well used 30 m See 71(4) for domestic or agricultural purposes, including water for livestock or for irrigation of crops NTZ 71(4) May reduce the NTZ under 71(3) if reasonably satisfied that the smaller zone will ensure that pesticide from the use will not enter the water supply intake or well Non-Glyphosate Applications 73(1) Around or along a body of water, dry stream, or classified wetland using any pesticide except glyphosate, subject to label restrictions and including all application methods Glyphosate Applications 74(1)(c) Along or around a body of water if the body of water is: non fish-bearing at any time of the year, and does not drain directly into a fishbearing body of water 10 m PFZ 2 m NTZ Glyphosate applications (see below) See 77(2) 74(1)(b) Along or around a body of water or a classified wetland that is: fish-bearing, or that drains directly into a 5 m PFZ See 77(2) 52

74(1)(a)(ii) fish-bearing body of water, or along or around a dry stream that when wet is fish bearing or that drains directly into a fish-bearing body of water Along or around a body of water or a classified wetland that is: fish-bearing, or that drains directly into a fish-bearing body of water, or along or around a dry stream that when wet is fish bearing or that drains directly into a fish-bearing body of water 74(2) Up to the high water mark of a temporary free-standing body of water and over a dry stream, that is: not fish-bearing at any time of the year does not drain directly into a fish-bearing body of water Noxious Weed & Invasive Plant Management All Uses 77(2) Selective application* to noxious weeds & invasive plants if the application is made between 1m & 10m above high water mark 77(1) Do not apply herbicides more than 1.5 m from a targeted plant 1m PFZ 2 m PFZ 0 m PFZ 1.5 m from a targeted weed or plant Glyphosate must be applied by selective application methods * 77(3) Must make reasonable efforts to identify sites where biological weed control organisms have been releases, and prevent harm to those organisms * To ensure that no-treatment zones are adhered to and to protect sensitivities such as watercourses, backpack application or wipe on/wicking applications would be utilized where applicable. Selective application would refer to the use of stem injection or wipe on/wicking where herbicide application to individual plants can be controlled. 5.3 Strategies for Protecting Fish and Wildlife, Riparian Areas and Wildlife Habitat [IPMR Section 58(3)(b)(ii)] KMC will implement strategies to protect fish and wildlife, riparian areas and wildlife habitat from potential adverse effects prior to control methods (chemical or non-chemical) being implemented under the IVMP for the facilities. 5.3.1 Strategies to Protect Riparian Areas The following strategies are to be implemented to prevent adverse effects to fish and wildlife, riparian areas, watercourses and wildlife habitat during invasive plant management (chemical and non-chemical). 53

Prior to control measures being implemented on pipeline ROWs and access roads to ROWs and facilities a Qualified Environmental Professional (QEP) will conduct pre-treatment inspections and identify the presence of environmental features for determination of whether implementation of pesticide-free zones is required. The QEP will determine the following items with respect to the proposed treatment site. Presence of water source or watercourse within 30 m. Presence of watercourse and/or associated riparian area within 10 m. Evaluation of whether the watercourse is fish-bearing or not; or drains directly to a fishbearing watercourse. This may be determined through a desktop assessment or identification in the field of a barrier to fish passage. As fish sampling may not be possible to confirm fish presence it may be required to default to a fish-bearing status. Presence of wildlife habitat within 10 m. Presence of native vegetation. Grazing concerns. The above information will be documented for each site in KMC s Pre Treatment Weed Monitoring Form. Based on the above evaluation the QEP will provide recommendations for the most appropriate treatment options (i.e. manual, mechanical, chemical.). KMC and or its QEP will review with their licensed contractors the occurrence of environmental sensitivities and the necessary protection measures for each site. QEPs will oversee treatment activities undertaken at sites with environmental sensitivities. Contract documents for vegetation management work in riparian areas shall include provisions for requirements for KMC s contractors to work with KMC s QEPs to ensure that the necessary environmental protection measures are adhered to. KMC and its licensed contractors will ensure that minimum protection measures are implemented with herbicide applications for bodies of water (temporary, permanent, fishbearing, not fish-bearing), dry streams, and classified wetlands are followed according to the requirements specified by the IPMR as identified in Table 20 in Section 20 of the IVMP. Boundaries for No-Treatment Zones and Pesticide-Free Zones as described in Table 20 are to be laid out and physically delineated with flagging by KMC staff, licensed contractor and/or the QEP prior to commencement of treatment activities at these sites. In addition to the buffers identified in Table 20 there should be no refueling of machinery, herbicide mixing or cleanup or disposal of herbicide material within 30 meters of watercourse. Additional to the prohibitions of herbicide use per the IPMR the BC Ministry of Forests, Lands, and Natural Resource Operations and Fisheries and Oceans Canada stipulates standards and best practices for maintenance of riparian vegetation in existing rights-of-way. These standards are outlined in the document Standards and Best Practices for Instream Works Public Utility Works http://www.env.gov.bc.ca/wld/instreamworks/publicutilityworks.htm#. This document outlines the following general standards. Maintenance activities must not damage more than one-third (1/3) of the total woody vegetation in the ROW, within 30 m of the high water mark of a watercourse. Management of vegetation within riparian areas of the ROW should be conducted manually or mechanically using hand-operated tools. 54

Works should avoid damage to the root structure of vegetation located on the bank of a watercourse. Restricting maintenance activities to comply with the above referenced standards would be applicable to native vegetation species and not that of noxious or invasive weeds. However, KMC and its contractors will ensure that whenever herbicide, manual or mechanical control methods are applied that efforts will be made to avoid disturbance to streamside vegetation that would result in impacts to bank stability that would lead to erosion and potential downstream sedimentation. Where vegetation management activities have resulted in disturbance to soils erosion and sediment control measures should be installed until vegetation has become re-established. Requirement for erosion and sediment control measures would be identified by the QEP. Adherence by the licensed contractor to the required environmental protection measures are to be documented by KMC and/or their QEP through completion of KMC s Post Treatment Monitoring Form for each site location. This will include confirmation that environmental features (i.e. watercourses and associated riparian areas) were observed and that treatment area boundaries were delineated.. 5.3.2 Strategies to Protect Wildlife and Habitat [IPMR Section 58(3)(b)(i)] Provisions of the Species at Risk Act, Migratory Bird Convention Act, and the BC Wildlife Act shall be adhered to. Fish, wildlife, plants and respective habitats that require protection are to be identified during the pre-treatment inspection to be conducted by KMC s QEP. This may reference to the Ministry of Environment s Conservations Data Centre http://www.env.gov.bc.ca/cdc/ for purposes of completing a search of the Species and Ecosystems Explorer prior to conducting pre-treatment inspections to identify known locations of species, ecological communities, Red and Blue listed species and ecological communities. The following strategies shall be implemented to protect wildlife and habitat when conducting the vegetation management activities on the pipeline ROWs and access roads to ROWs and facilities. A QEP shall survey treatment sites to determine the presence of wildlife and/or wildlife habitat. Bird nest surveys should be conducted by a QEP prior to any vegetation management activities conducted during the migratory bird breeding season could impact active nest sites. The bird breeding season varies depending on the region of the province; however, it is generally March to August. A Pesticide-Free Zone should be established and maintained around all wildlife trees showing active use by birds (i.e. nesting birds, active feeding). This should be directed by the QEP. During pre-treatment site assessments the QEP should assess the sites for presence of indicator habitat and potential presence of Species At Risk. Vegetation management activities should avoid impacts to federally listed species (direct or indirect). PFZs and NTZs shall be determined by a QEP and established/maintained as required around inhabited raptor and heron nests, wildlife trees, susceptible amphibians and wildlife; 55

Soil erosion shall be minimized during vegetation management activities so as to minimize impacts on desirable vegetation. 5.4 Strategies to Prevent Herbicide Contamination of Food Intended for Human Consumption [IPMR Section 58(3)(b)(iii)] KMC facilities are occasionally located near environmentally sensitive areas such as lawns, vegetable gardens, berry picking and bee keeping areas, and areas containing agricultural crops and domestic animals. Food intended for human consumption is sometimes grown or found within these areas. Because they are sometimes found adjacent to problem vegetation that may be targeted for control, the following strategies shall be implemented for their protection: Non-chemical methods of vegetation management shall be considered where treatment objectives can be achieved; Where possible, areas containing food plants for human consumption (including berries, medicinal plants and organic farms) shall be identified and documented; If control methods involving the application of herbicides are required, PFZs shall be maintained around these areas during herbicide application; Treatment notices shall be posted at public access points to proposed treatment areas advising of treatment near food crops. This will ensure that people are aware that the area has been treated with herbicides; and, Where possible, herbicide treatments shall be conducted at times to minimize impacts on food plants. There is also the expectation that organic farmers will have established well maintained adequate buffer zones from problem vegetation, noxious weeds and invasive plants to reduce the potential use of herbicides near the organic property. 5.5 Pre-Treatment Inspection Procedures for Identifying Treatment Area Boundaries [IPMR Section 58(3)(b)(iv)] The following procedures shall be implemented to ensure that treatment area boundaries are identified and clearly marked prior to herbicide applications: A pre-treatment inspection shall be conducted to establish treatment boundaries and to document the location of environmentally sensitive areas; Treatment area boundaries and the location of environmentally sensitive features shall be mapped; A pre-treatment meeting shall be held between the contractor and KMC or third party consultants to confirm treatment area boundaries and the locations of environmentally sensitive features; and, Marking/flagging of all PFZs and NTZs shall be completed, and the contractor instructed to observe these areas, prior to herbicide application. The marking/flagging shall be maintained until the completion of herbicide application. 56

5.6 Procedures for Maintaining and Calibrating Herbicide Application Equipment [IPMR Section 58(3)(b)(v)] All herbicide application equipment used on KMC property shall be safe, clean, in good repair, compatible and appropriate for the herbicide being used. As a minimum, all back sprayers and handguns (power hose and nozzle) shall be calibrated once per year prior to use, and at regular intervals throughout the season. Sprayers shall be re-calibrated when nozzle output begins to vary. The frequency of sprayer calibration shall be dictated by factors such as formulation of herbicides used. For example, abrasive formulations such as wettable powders normally result in greater nozzle wear and will require more frequent calibrations. 5.7 Procedures for Monitoring Weather Conditions and Strategies for Modifying Herbicide Application Methods for Different Weather Conditions [IPMR Section 58(3)(b)(vi)] 5.7.1 Weather Monitoring Measurements shall be made by the Contractor to record weather conditions prior to, and periodically during, herbicide applications. Wind speed and direction, precipitation, temperature and sky conditions (clear, overcast, cloudy, partly cloudy), and frost and dew conditions shall be recorded for all herbicide applications. Persons applying herbicides are responsible for checking each product label for guidelines for applying herbicides under various weather conditions. 5.7.2 Stop Treatment Conditions Herbicide applications shall be stopped if: The maximum/minimum temperature stated on the herbicide label is exceeded; or The wind speed and/or direction cause the foliar or soil application of herbicide to drift and/or miss the target vegetation; or, Ground wind velocity is over 8 km/hour; or It begins to rain steadily, increasing the chances of excessive runoff and leaching; or, There is ice or frost on the foliage. 6.0 REPORTING, NOTIFICATION AND CONSULTATION 6.1 Reporting Accurate record keeping allow KMC and the Administrator, IPMA, to monitor the quantity of pesticides used, and to ensure compliance with the IPMA and IPMR, the commitments made in this IVMP, and the contents of the Pesticide Use Notice. KMC will ensure that each of the required records described below are maintained. 57

6.1.1 Confirmation Holder Use Records Each contracting firm that applies herbicides for KMC must maintain daily records of herbicide use. Section 37(1) of the IPMR describes the requirements for these records. The following records must be kept for each treatment location and day of use: The date and time of the herbicide use; The name of the pest targeted by the use or the purpose of the herbicide use; The trade name of each pesticide used and its registration number under the federal PCPA; For each herbicide used, the method and rate of application and the total quantity used; The prevailing meteorological conditions including temperature, precipitation and velocity and direction of the wind, these conditions should be measured at the beginning of each day before starting treatment, re-measured if obvious changes in environmental conditions occur throughout the day, and re-measured at the end of any treatment day; and, A record for each piece of the holder s herbicide application equipment that requires calibration showing when the equipment was calibrated and the data upon which its calibration was based. 6.1.2 Annual Report for Confirmation Holders In accordance with Section 39 of the IPMR, KMC will provide to the Regional Administrator, IPMA, the following information for a calendar year by January 31 in the next calendar year for operations conducted under this IVMP during the calendar year: The name and address of the confirmation holder, and their confirmation number; Trade name and active ingredient of the herbicide(s) applied, including their PCP #s; Total area treated; and, Quantity of each active ingredient applied (kg). 6.2 Notifications KMC commits to providing the following notifications with respect to this IVMP: 6.2.1 Notification of IVMP Confirmation KMC will, within 7 days of the plan confirmation date, make available, for the term of the confirmation, a copy of the confirmation and the IVMP with relevant maps at their local offices to allow inspection by the public. 6.2.2 Annual Notice of Intent to Treat As per section 42 of the IPMR, for the purpose of an annual Notice of Intent to treat, KMC will prepare and retain a detailed map showing the treatment locations for the applicable calendar year, which indicate the following for each treatment location: The proposed treatment areas; and The geographic features that require a pesticide-free zone or a no-treatment zone. 58

KMC will forward, in writing, to the B.C. Ministry of Environment, at least 21 days prior to treatment in each year during which the IVMP is in effect, an Annual Notice of Intent to Treat (NIT) for the following year. This NIT will identify: Name and business location of confirmation holder; Proposed treatment areas; Proposed treatments; Pesticides proposed for use and their method of application; and, The total area proposed for treatment. 6.2.3 Requests to Amend the IVMP KMC will forward, in writing, to the Ministry of Environment, amendments requested for the IVMP. Amendment requests to add new application techniques or similar changes will not require further public consultation, provided that the amendment request is within land owned or controlled by KMC. Amendments to add new active ingredients will require further public consultation. 6.2.4 Notification of Contraventions Section 72(1)(d) of the IPMR requires that a confirmation holder give written notice to the administrator on a contravention of the IPMA or IPMR that involves the release of a pesticide into the environment. KMC commits to abiding by this requirement. In addition, KMC has implemented contractor guidelines to ensure compliance. Failure of the contractor to observe the following requirements may be cause for contractor dismissal: Violation of the requirements of the IPMA or the IPMR; Mixing of herbicides in inappropriate locations such as near environmentally sensitive zones; Failure to use adequate personal protective equipment when required by the product label; Application of herbicides within prohibited zones; Improper cleanup or reporting of spills; Application of herbicides by uncertified personnel without appropriate supervision; Improper disposal of unused herbicides or containers; Improper equipment calibration; Application of herbicides under inappropriate or unsafe conditions; Failure to properly complete and submit daily operating logs or records; Handling, storing, mixing, transporting, or applying herbicides in a manner which violates product labels; or, Behaviour likely to result in discredit to KMC. 6.2.5 Public Notification Prior to Treatment Notification of individuals, communities and organizations in the time and manner as agreed during the public consultation process, will be completed prior to treatments. KMC will maintain a record of all public notifications for each treatment area. 6.2.6 Posting of Treatment Notices Prior to treatment, posted signs will be posted in locations so that they are clearly visible and legible from each approach maintained by KMC for use by the public, employees, or contractors 59

to access the treatment area or at locations where due diligence would seem to require them. The signs shall remain posted for 14 days following pesticide application, and contain the following information: The trade name or active ingredient of the herbicide that will be used; The date and time of the herbicide use; Precautions to be taken to prevent harm to people entering the treatment area; The confirmation number of the KMC IVMP; How to contact KMC to obtain additional information about the herbicide or herbicide use; and, For each treatment location, the applicator will maintain a record of where notices were posted. The following is an example of a typical sign used for notification of treatment. 6.3 Consultations 6.3.1 Public Consultation Plan Prior to submitting a Pesticide Use Notice to the Ministry of Environment for IVMP confirmation, KMC will carry out a consultation process with the public and individuals adjacent to KMC property potentially significantly affected by the IVMP. The objectives of conducting consultations when this IVMP is at the draft stage are: To increase public awareness of the IVMP process and of the principles of IVM which are embodied in the IVMP; To ensure that the public have an opportunity to identify concerns, and for KMC to address those concerns, before the IVMP is finalized and submitted and a Pesticide Use Notice submitted for confirmation; To ensure a transparent and accountable review process for the IVMP; To educate the public on the need to manage problem vegetation, noxious weeds and invasive plants; and, To explain how the planning process that is described in the IVMP recognizes the need to protect human health and the environment. As per Section 61(1) of the IPMR, at least 45 days before submitting a Pesticide Use Notice, the first of 2 notices, at least 40 cm² in size, will be published within a 2 week period in newspapers circulated in the various communities (or nearest communities). The published advertisements shall be placed in the main or legal sections of the newspapers with the heading DEVELOPMENT OF A PEST MANAGEMENT PLAN. The notices shall cover a minimum of 40 cm², and contain the following information: (a) Pest Management Plan number, (b) name, address, telephone and fax number of the PMP applicant, (c) purpose(s) of proposed pest management, (d) all pest management methods in the proposed Pest Management Plan (pesticide and nonpesticide), (e) proposed geographic area of, and description/distance from the nearest community to the proposed area, (f) trade name and common name of all proposed pesticides, 60

(g) commencement and completion for the PMP, (h) location where the PMP application and maps of the proposed treatment areas may be examined in detail, and (j) the paragraph : A person wishing to contribute information about a treatment site, relevant to the development of the pest management plan, may send copies of the information to the applicant at the address above within 30 days of the publication of this notice During the public consultation process, the draft IVMP will be accessible by the public, as stated in the public notifications and on the KMC website to allow the public to view and download the IVMP text and the maps. 6.3.2 Public Consultation Report KMC will prepare and submit, if requested by the Administrator, IPMA, and a Public Consultation Report that contains: A summary of public consultations, including the names and addresses of those who provided input, the nature of their concerns and/or recommendations, and the KMC response to the input from the public: and, A list of newspapers in which notification of the pending IVMP submission appeared, publication dates and a photocopy or tear sheet of a representative advertisement. 6.3.3 First Nations Consultations KMC has been advised by the BC Ministry of Environment that the requirement to conduct First Nations consultation had been waived, because the proposed treatment areas (i.e. KMC facilities) were all fenced compounds that had physically restricted access. 61

Appendices 62

Appendix 1: List of KMC Facility Names, Locations and Facility Types Facility Name Facility Location Facility Type Jet Fuel On Grauer Bypass Road, Vancouver Airport Terminal Terminal Westridge On the south shore of Burrard Inlet in Burnaby, at the N end of Bayview Drive, 100 m from the junction of Terminal Burnaby Bayview Drive and Hwy 7A (Inlet Drive) North of Shellmont Street in Burnaby Terminal. Access to the site is via a paved road and access gate on Underhill Avenue. Terminal, Tank Farm and Maintenance Facility Port Kells On the 9400 Block of 189th Street, Langley Pump Station Port Kells 18877 86th Avenue Langley Valve Station Valve Station Sumas Off Whatcom Road, Sumas Valve Station Sumas East side of McDermott Road, Sumas Pump Station Sumas On Upper Sumas Mountain Road, Sumas Tank Farm Wahleach Hope On the south side of Bridal Falls Road, 0.5 km west of Trans-Canada Highway exit 141 Between 6th and 7th Avenues, south of the Old Hope- Princeton Highway, Hope Pump Station Tank Farm and Maintenance Facility Kingsvale East side of Coldwater Road, 27 km south of Merritt Pump Station Merritt Station The station is located 250 m E from the junction of Coldwater Road and Highway 5A (Okanagan- Connector), Merritt Abandoned Station Stump Lake 4 km west off Highway 5A (Old Kamloops/Merritt) by Stump Lake Pump Station Petrocan North side of Tranquille Road at the Kamloops Airport Takeoff Takeoff Kamloops 2355 Trans- Canada Highway, Kamloops Tank Farm and Maintenance Facility Black Pines Adjacent to the Westside Barriere Road, 6 km South of McLure Ferry Road Valve Station Darfield East side of Highway 5, 29 km north of Barriere Pump Station Blackpool East side of Highway 5, south of the community of Blackpool Pump Station McMurphy North side of Highway 5, 17 km south of Avola Pump Station Pump Station 63

Finn East side of Highway 5, 16 km north of Avola Pump Station Blue River East side of Highway 5, in Blue River Pump Station and Maintenance Facility Chappel East side of Highway 5, 20.2 km north of Blue River Pump Station Pump Station Albreda East side of Highway 5, in the community of Albreda Pump Rearguard Hargreaves Pump Station The pump station is located on the S side of the Highway 16, 8.5 km E of the junction of Highways 5 and 16. Access is via a gravel access from Highway 16. On Highway 16, 22 km East of the junction of Highway 16 and Highway 5 Station Pump Station Trap Site 64

Appendix 2: Maps of the KMC Pipeline Systems in British Columbia Showing Locations of Facilities 65

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Appendix 3: KMC Facilities Pre-Treatment Weed Monitoring Form for Problem Vegetation, Noxious Weeds and Invasive Plants PRE TREATMENT ROW KMC WEED MONITORING FORM Page 1 - Site Assessment Date: Name: Surrounding Land Use: Facility / KP: Photos: Pre-Weed Control Species Observed (corresponds to site sketch) Growth stage (Seedling/Juvenile/ Mature) Density Code (1-9) Designation (Prohibited Noxious / Noxious) Plant Category (1-4) 1. On site Adjacent 2. On site Adjacent 3. On site Adjacent 4. On site Adjacent 5. On site Adjacent Vegetation Pasture/Hay/Forested % Ground cover: Onsite Off ROW (~10 to 30m adjacent to site) 0-35% 0-35% 35-75% 35-75% 75-100% 75-100% Cultivated / Crop Land Type of Crop: Comments / Issues: 71

Page 2 - Course of Action TREATMENT THRESHOLDS FOR THE NOXIOUS WEED AND INVASIVE PLANT PROGRAM Invasive Plant Category Site Risk Level 1 2 3 1 Priority 1 Priority 1 Priority 1 2 Priority 2 Priority 3 Priority 4 3 Priority 2 Priority 3 Priority 4 4 Priority 3 Priority 4 Priority 5 Not assigned Priority 4 Priority 5 Priority 5 As the above table shows, the priority assigned to an invasive plant infestation is determined by the plant category and the site priority. Plant Category: Categories are based on provincial rankings in AB and BC. Weed species are categorized according to aggressiveness, range of habitat and the ability to control. 1- weeds are described as extremely invasive and often are the most abundant species in the area. 2- weed species are described as very invasive and can become very prevalent in an area. 3- weeds are described as being invasive and often require some disturbance to establish. 4- weeds are aggressive and relatively easy to control. Not assigned - little concern or likelihood to appear in a specific region. Site Risk Level: 1 - Extremely high risk: To stop the spread of invasive plants threatening non-infested, highly susceptible areas. 2 - To stop the enlargement of sites in less susceptible areas. This includes sites adjacent to lands such as forested lands that have a well-established vegetation cover, and are therefore less susceptible to invasive or seed species introduction. Weedy areas along a right-of-way will be considered to be a Priority 1 if a vegetation specialist identifies a high potential for the noxious weeds or invasive plants to spread off the right-of-way and invade adjacent lands. 3 - Stop the enlargement/contain sites on, and adjacent to, industrial lands. Treatment Priority: 1-3: Is treatment priority 1 to 3 If yes, recommend CONTROL METHOD 4-5: Is treatment priority 4 or 5? If yes, recommend PREVENTION METHOD It must be recognized that treatment priorities may change as new species are identified as being detrimental to biodiversity, natural plant communities, adjacent agricultural land, or as land uses change. Environmental Features (PFZ) Water source/water body within 30 m yes no comments: Water body/riparian area within 10 m yes no comments: Site requiring protection yes no comments: Wildlife habitat within 10 m yes no comments: Native plants present yes no comments: Grazing concerns yes no comments: 72

Accessibility (circle) Other: good / fair / poor comments: Treatment Options Prevention Methods (circle): Rationale/Comments: seeding / mechanical / chemical / biological Control Methods (circle): Rationale/Comments: mechanical / chemical / biological 73

Sketch/Map of Site Location of Weeds 74

WEED DENSITY DISTRIBUTION CODES Guidelines for Field Assessment* Description No. of plants in 20 x 20 m area (low shrubs, herbs and mosses) No. of plants/ha 100 x 100 m area (tall shrubs and trees) Diagram Approximate % Cover Range rare individual, a single occurrence 1 <5 1-5 a few sporadically occurring individuals 2-5 5-50 1-5 a single patch or clump of species 1 patch (occupying an area smaller than on quadrant of the plot) variable (3 patches) 1-10 several sporadically occurring individuals 6 >50 5-10 a few patches or clumps of species 2-5 patches (each occupying an area smaller than one quadrant of the plot) variable (3-10 patches) 10-30 several well-spaced patches or clumps 6 patches (each occupying less than one quadrant of the plot) variable (10-many disjunct patches) 10-30 continuous uniform occurrence off well-spaced individuals many many 10-30 continuous occurrence of a species with a few gaps in the distribution many many (continuous matrix formed by species crowns with some openings) 30-60 continuous dense occurrence of a species many many > 60 Note: The distribution code is determined over a sufficiently large area to account for normal variation in distribution pattern. 75

Appendix 4: KMC Post-Treatment(s) Monitoring Form KMC Post-Treatment Monitoring Form Date: Date: Name: Surrounding Land Use: Facility / KP (ROW): Photos Treatment Info: Date of Treatment: Area Treated (ha): Methods: Chemical / Mechanical / Other Licensee Name: Licence #: Address: Phone #: Application Equipment: Chemical Summary Product Name Active Ingredient PCP # Target Species App. Rate (L/ha) Total Vol. (L) Wind Speed: Temperature: Notes: Non-chemical Summary Treatment Used: Description: Environmental Protection Required pesticide free zones were marked Required pesticide free zones were maintained Treatment area boundaries were marked Treatment area boundary markings were adequate Treatment notices posted Water source/waterbody within 30 m were observed Waterbody/riparian area within 10 m were observed Wildlife habitat within 10 m were observed Native plants were observed yes no comments: yes no comments: yes no comments: yes no comments: yes no comments: yes no comments: yes no comments: yes no comments: yes no comments: 76

Off site pesticide movement observed yes no comments: Non-target effects observed yes no comments: Other: The contractor is not required to use KMC's Treatment Form only if a suitable alternate treatment form is used to document similar information. It is suggested that each contractor be provided with a copy of the Weed Monitoring Form and a copy of the KMC IVMP, when working in BC, so that they are aware of which of their activities will be inspected/monitored. 77

Appendix 5: Weeds of Management Concern for the Trans Mountain Pipeline System Common Name Scientific Name Alberta Rank BC Rank Alberta JNP MRPP Fraser-Fort George Thompson - Nichola Anchusa Anchusa officinalis -- -- -- Category 3 Category 3 Category 3 Category 3 annual sow-thistle Baby's breath Sonchus asper (L.) Hill Gypsophila paniculata -- Noxious Category 3 Category 1 Category 3 Category 3 Category 3 -- -- -- Category 3 Category 3 Category 3 Category 3 Fraser Valley Category 3 Category 3 Category 3 ball mustard Neslia paniculata -- -- Category 4 Category 4 Category 4 Category 4 Category Category 4 4 biennial campion Silene cserei -- -- Category 4 -- -- -- -- -- bird rape (Polish canola) Brassica rapa -- -- -- -- -- -- -- -- black knapweed Centaurea nigra L. Prohibited Noxious -- -- Category 1 Category 1 Category 1 Category 1 black medick Medicago lupulina -- -- Category 4 Category 4 Category 4 Category 4 Category 4 bladder campion Silene cucubalus Wibel -- -- Category 3 Category 2 Category 4 Category 4 Category 4 bluebur Lappula squarrosa -- -- Category 2 Category 2 Category 4 Category 4 Category 4 blueweed broom Echium vulgare L. Cytisus scoparius (L.) Link brown knapweed Centaurea jacea L. Prohibited Noxious bull thistle Cirsium vulgare (Savi) Ten. Noxious Noxious Category 2 Category 2 Category 2 Category 2 Category 2 -- -- -- Category 1 Category 1 Category 1 Category 1 -- -- Category 1 Category 1 Category 1 Category 1 -- -- -- Category 3 Category 3 Category 3 Category 3 Category 1 Category 4 Category 4 Category 4 Category 2 Category 1 Category 1 Category 3 burdock Arctium spp. Noxious Noxious Category 2 Category 2 Category 2 Category 2 Category Category 2 2 kochia Kochia scoparia -- -- Category 2 Category 2 -- -- -- -- caragana Caragana -- -- -- Category 4 -- -- -- -- arborescens wild caraway Carum carvi -- -- -- Category 3 -- -- -- -- cleavers Galium aparine L. -- -- Category 3 Category 3 -- -- -- -- and Galium spurium L. white/dutch clover Trifolium repens -- -- -- Category 2 Category 2 -- -- -- common chickweed Stellaria media -- -- Category 4 -- -- -- -- -- common crupina common dandelion common knotweed common mullein Crupina vulgaris Cass. Taraxacum officinale Polygonum arenastrum Verbascum thapsus Prohibited Noxious -- -- -- -- -- -- Noxious -- -- -- Category 3 -- -- -- -- -- -- -- Category 2 Category 1 Category 1 Category 1 Noxious -- Category 4 Category 1 Category 4 Category 4 Category 4 Category 1 Category 4 common plantain Plantago major -- -- -- Category 2 -- -- -- -- common tansy Tanacetum vulgare Noxious -- Category 2 Category 1 Category 1 Category 1 Category Category 1 L. 1 common timothy Phleum pratense -- -- -- Category 3 Category 3 -- -- -- corn spurry Spergula arvensis -- -- -- -- -- -- -- -- cotoneaster Cotoneaster spp. -- -- -- Category 4 -- -- -- -- cow cockle Saponaria vaccaria -- -- Category 3 -- -- -- -- -- 78

Thompson - Nichola Common Name Scientific Name Alberta Rank BC Rank Alberta JNP MRPP Fraser-Fort George Fraser Valley creeping Cirsium arvense Noxious Noxious Category 2 Category 1 Category 2 Category 2 Category Category 2 (Canada) thistle (L.) Scop. 2 creeping Campanula Noxious -- Category 4 Category 4 Category 4 Category 4 Category Category 4 bellflower rapunculoides 4 cypress spurge Euphorbia -- -- Category 1 Category 1 Category 1 Category 1 Category Category 1 cyparissias L. 1 Dalmatian Linaria vulgaris Noxious Noxious Category 1 Category 1 Category 1 Category 1 Category Category 1 toadflax Hill. 1 diffuse Centaurea diffusa Prohibited Noxious Category 1 Category 1 Category 2 Category 2 Category Category 2 knapweed Lam. Noxious 2 dodder Cuscuta spp. -- Noxious Category 1 Category 3 Category 3 -- -- -- dog mustard Category 4 Erucastrum gallicum -- -- Category 4 Category 1 Category 1 Category 4 Category 4 downy brome Bromus tectorum Noxious -- Category 1 Category 1 Category 1 Category 1 Category 1 dwarf snapdragon Eurasian water milfoil false flax, small seeded field bindweed field chickweed Chaenorhinum minus Myriophyllum spicatum L. Camelina microcarpa Convolvulus arvensis L. Cerastium arvense Category 1 -- -- -- Category 2 Category 2 -- -- -- Prohibited -- Category 1 -- -- -- -- -- Noxious -- -- Category 3 -- -- -- -- -- Noxious -- Category 2 -- -- -- -- -- -- -- Category 4 -- -- -- -- -- field scabious Knautia arvensis Noxious Noxious Category 2 Category 1 Category 1 Category 1 Category Category 1 1 flixweed Descurainia -- -- Category 3 Category 1 Category 1 -- -- -- sophia foxtail barley Hordeum jubatum -- -- Category 3 Category 1 Category 1 Category 4 Category Category 4 4 garden rhubarb Rheum rhabarbarum -- -- -- Category 2 -- -- -- -- Giant knotweed goat s beard Polygonum sachalinense Tragopogon dubius -- -- -- Category 3 Category 3 Category 3 Category 3 -- -- Category 3 Category 1 Category 3 Category 3 Category 3 gorse Ulex europaeus -- -- -- Category 1 Category 1 Category 1 Category 1 greater knapweed Centaurea scabiosa -- -- -- Category 1 Category 1 Category 1 Category 1 green foxtail Setaria viridis -- -- Category 3 -- -- -- -- -- green tansy Descurainia -- -- Category 4 -- -- -- -- -- mustard pinnata hare's ear mustard Conringia orientalis hawkweed Hieracium spp. Prohibited Noxious hedge bindweed Convolvulus sepium Category 3 Category 3 Category 1 Category 1 -- -- Category 4 -- -- -- -- -- -- Category 4 Category 1 Category 1 Category 1 Category 1 Category 1 -- -- Category 3 -- -- -- -- -- hemp-nettle Galeopsis tetrahit -- -- Category 3 Category 1 Category 1 Category 4 Category Category 4 4 henbit Lamium -- -- Category 4 -- -- -- -- -- amplexicaule hoary alyssum Berteroa incana -- -- -- Category 3 Category 3 Category 3 Category Category 3 3 hoary cress Cardaria spp. Noxious Noxious Category 2 Category 2 Category 2 -- Category 2 -- 79

Common Name hound s-tongue Japanese knotweed jointed goatgrass Kentucky bluegrass knawel Scientific Name Alberta Rank BC Rank Alberta JNP MRPP Fraser-Fort George Thompson - Nichola Fraser Valley Cynoglossum Noxious Noxious Category 2 Category 2 Category 2 Category 2 Category Category 2 officinale L. 2 Polygonum -- -- -- Category 3 Category 3 Category 3 Category Category 3 cuspidatum 3 Aegilops cylindrica Prohibited Noxious -- -- -- -- -- -- Host Noxious Poa pratensis -- -- -- Category 4 -- -- -- -- Scleranthus annuus L. -- -- Category 2 -- -- -- -- -- knotweed Polygonum spp. Prohibited -- -- -- Category 1 Category 1 -- Category 1 Noxious lady s thumb Polygonum persicaria -- -- -- Category 2 -- -- -- -- lamb's-quarters Chenopodium album -- -- Category 4 Category 2 Category 4 Category 4 Category 4 leafy spurge Euphorbia esula L. Noxious Noxious Category 1 Category 1 Category 1 Category 1 Category 1 loosestrife Lythrum spp. Prohibited Noxious -- Category 2 Category 2 Category 2 Category 2 Category 2 Category 4 Category 1 Category 2 marijuana Cannabis sativa -- -- -- -- -- -- -- -- marsh plume Cirsium palustre Prohibited Noxious -- Category 1 Category 1 Category 1 Category Category 1 thistle (L.) Scop. Noxious 1 meadow hawkweed Meadow Knapweed Mouse-eared chickweed Mouse-eared narrow-leaf hawks-beard Night-flowering catchfly Hieracium pilosella L. Centaurea pratensis Cerastium vulgatum Prohibited Noxious -- Category 4 Category 1 Category 1 Category 1 Category 1 Category 1 -- -- -- Category 3 Category 3 Category 3 Category Category 3 3 -- -- Category 4 -- -- -- -- -- Crepis tectorum -- -- Category 3 Category 3 Category 3 Category 3 Category 4 Silene noctiflora -- -- Category 3 Category 3 Category 3 Category 3 Category 3 nodding thistle Carduus nutans L. Prohibited Noxious orange hawkweed Hieracium aurantiacum L. -- Category 1 Category 1 Category 1 Category 4 Category 4 -- Noxious Category 4 Category 1 Category 1 Category 1 Category 1 Category 4 Category 3 Category 4 Category 1 orchard grass Dactylis glomerata -- -- -- Category 4 -- -- -- -- oxeye daisy Leucanthemum Noxious Noxious Category 2 Category 1 Category 2 Category 2 Category Category 2 vulgare Lam. 2 perennial pepperweed perennial sow thistle Persian darnel pineappleweed plumeless thistle Lepidium latifolium L. Sonchus arvensis L. Lolium persicum Boiss. & Hohen. Matricaria matricarioides Carduus acanthoides L. Noxious Noxious -- -- -- -- Category 4 -- Noxious Noxious Category 2 Category 2 Category 3 Category 3 Category Category 3 3 -- -- Category 3 -- -- -- -- -- -- -- Category 4 Category 3 Category 4 Category 4 Category 4 Prohibited Noxious -- -- Category 2 Category 2 Category 2 Category 2 Category 4 Category 2 poverty weed Iva axillaris -- -- -- -- -- -- -- puncturevine Tribulus terrestris Prohibited -- Category 3 Category 3 Category 3 Category 3 Category Category 3 L. Noxious 3 purple cockle Agrostemma githago -- -- -- -- -- -- 80

Thompson - Nichola Common Name Scientific Name Alberta Rank BC Rank Alberta JNP MRPP Fraser-Fort George Fraser Valley purple Lythrum salicaria Prohibited -- Category 2 Category 2 Category 2 Category 2 Category Category 2 loosestrife L. Noxious 2 purple nutsedge Cyperus rotundus -- Noxious Category 3 Category 3 Category 3 Category 3 Category Category 3 L. 3 quack grass Elytrigia repens -- Category 3 -- -- -- -- -- ragweed -- Category 4 -- -- -- -- -- Ambrosia artemisiifolia ragwort Senecio viscosus -- -- Category 2 Category 2 Category 2 Category 2 red bartsia redroot pigweed redseed dandelion Rough cinquefoil round-leaved mallow rush skeletonweed Russian knapweed Russian pigweed Russian thistle scentless chamomile Odontites serotina Dum. Amaranthus retroflexus Taraxacum laevigatum Potentilla norvegica Prohibited Noxious -- Category 1 Category 2 Category 2 Category 2 Category 2 Category 2 Category 2 -- Category 4 -- -- -- -- -- -- -- Category 3 -- -- -- -- -- Category 4 Category 2 Category 4 Category 4 Category 4 Category 4 Malva rotundifolia -- Category 4 -- -- -- -- -- Chondrilla juncea L. Centaurea repens L. Axyris amaranthoides Salsola pestifer (kali) Matricaria perforata Merat. Prohibited Noxious Noxious Category 3 Category 3 Category 3 Category 3 Category 3 Category 3 Prohibited -- Category 2 Category 2 Category 2 Category 2 Category 2 Category 2 Noxious -- Category 3 Category 1 Category 1 -- -- -- -- Category 3 Category 2 Category 2 -- -- -- Noxious Noxious Category 2 Category 1 Category 2 Category 2 Category 2 Category 2 Scotch broom Cytisus scoparius -- scotch thistle Onopordum -- -- -- -- -- -- -- -- acanthium L. Shepherd s Capsella bursapastoris -- Category 3 Category 1 Category 1 -- -- -- purse Silvery cinquefoil Potentilla argentea -- -- Category 2 Category 2 Category 4 Category 4 Category 4 spotted knapweed spreading dogbane St. John's wort Centaurea maculosa Lam. Apocynum androsaemifolium L. Hypericum perforatum L. Prohibited Noxious Category 1 Category 1 Category 1 Category 1 Category 1 Category 1 Noxious -- -- Category 3 Category 3 Category 3 -- -- -- Prohibited Nox. -- Category 4 Category 4 Category 4 Category 4 Category 4 Category 4 Stinkweed Thlaspi arvense -- Category 4 Category 2 Category 4 Category 4 Category 4 Category 4 stork s bill Erodium -- -- Category 2 Category 3 -- -- -- -- cicutarium (L.) L Her. sulphur Potentilla recta L. Prohibited Noxious -- Category 4 Category 4 Category 4 Category 2 Category 4 cinquefoil Noxious tall buttercup Ranunculus acris Noxious -- Category 2 Category 1 Category 4 Category 4 Category 4 Category 4 L. Tall hedge mustard Sisymbrium loeselii -- Category 4 Category 1 Category 1 Category 4 Category 4 Category 4 tansy ragwort tartary buckwheat Senecio jacobaea L. Fagopyrum tataricum Teasel Dipsacus fullonum -- Prohibited Noxious -- Category 2 Category 2 Category 2 Category 2 Category 1 Noxious -- Category 4 Category 4 Category 4 Category 4 Category 4 Category 4 81

Common Name Scientific Name Alberta Rank BC Rank Alberta JNP MRPP Fraser-Fort George Thompson- Nichola Fraser Valley Tufted vetch Vicia cracca -- -- Category 1 Category 1 Category 4 Category 4 Category 4 tumbling mustard Sisymbrium -- Category 4 Category 4 Category 4 Category 4 Category 4 Category 4 alstissimum velvetleaf Abutilon -- Noxious -- -- Category 4 Category 4 Category 4 Category 4 theophrasti Medik. white cockle Silene alba (Mill.) Noxious -- Category 2 Category 1 Category 4 Category 4 Category 4 Category 4 E. H. L. Krause white sweet Melilotus alba -- -- Category 1 Category 1 Category 2 -- -- clover Wild buckwheat Polygonum -- Category 4 Category 2 Category 4 Category 4 Category 4 Category 4 convolvulus wild chervil Anthriscus -- Noxious Category 3 Category 3 Category 3 Category 3 Category 3 Category 1 sylvestris L. Hoffmann wild mustard Sinapsis arvensis -- Category 4 Category 4 Category 4 Category 4 Category 4 Category 4 (Brassica kaber) wild oats Avena fatua -- Noxious Category 4 Category 3 -- -- -- -- wild radish Raphanus raphanistrum -- Category 4 Category 4 Category 4 Category 4 Category 4 Category 4 wormseed mustard wormwood; absinth Erysimum cheiranthoides Artemisia absinthium -- Category 4 Category 4 Category 4 Category 4 Category 4 Category 4 -- Category 3 Category 3 Category 3 Category 3 Category 3 Category 3 Yellow clematis Clematis tangutica Noxious Category 3 Category 1 Category 3 Category 3 Category 3 Category 3 yellow iris Iris pseudacorus Prohibited -- Category 3 Category 3 Category 1 Category 3 Category 3 Category 3 L. Noxious yellow nutsedge yellow starthistle yellow sweet clover yellow toadflax Cyperus esculentus L. Centaurea solstitialis L. Melilotus officinalis Linaria vulgaris (P.) Mill. Prohibited Noxious Noxious Category 3 Category 3 Category 3 Category 3 Category 3 Category 3 Prohibited Noxious Category 1 Category 1 Category 1 Category 1 Category 1 Category 1 Noxious -- -- Category 1 Category 2 -- -- -- Noxious Noxious Category 2 Category 1 Category 3 Category 3 Category 3 Category 3 82