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DOC EFP Staff Comments and Recommendations PUC Docket E002/TL-11-223 Page 9 engineering principles and system reliability is not compromised. EFP staff proposes the following addition to Permit Section 4.2.5: 9.2.5. Vegetation Removal in the Right-of-Way The Permittees shall minimize the number of trees to be removed in selecting the right-of-way specifically preserving to the maximum extent practicable windbreaks, shelterbelts, living snow fences and vegetation in areas such as trail and stream crossings, where vegetative screening may minimize aesthetic impacts, to the extent that such actions do not violate sound engineering principles or system reliability criteria. Tall tree species located within the transmission line right-of-way that endanger the safe and reliable operation of the transmission facility will be removed. In many cases certain low and slow growing species that do not exceed a mature height of 15 feet can be planted in the right-of-way to blend the difference between the right-of-way and adjacent wooded areas, to the extent that the low growing vegetation that will not pose a threat to the transmission facility or impede construction. EFP staff proposes the following addition to Permit Section 4.2.8: 4.2.8. Wetlands and Water Resources Structures shall be located to span watercourses, wetlands, and floodplain to the extent practicable and consistent with sound engineering principles. Minimal grading of areas around pole locations may be required to accommodate construction vehicles and equipment. Construction of Public Water crossings shall be consistent with construction methods identified in Minn. Rule 6135.1300, as required by the Minnesota Department of Natural Resources in the License to Cross Public Lands and Waters. Permittee shall minimize disturbance to natural streambed and shoreline vegetation and restrict clearance of banks, shorelines and adjacent lands to the minimum necessary for equipment to complete the installation to the extent that such actions do not violate sound engineering principles or system reliability criteria. The Permittees shall endeavor to access wetlands and riparian areas using the shortest route possible in order to minimize travel through wetland areas and prevent unnecessary impacts wherever possible. Construction in wetlands and riparian areas shall be scheduled during frozen ground conditions, when practicable. When construction during winter is not possible, construction mats (wooden mats or a composite mat system) shall be used to protect wetland vegetation. All-terrain construction vehicles designed to minimize soil impact in damp areas may also be used