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44-051 100 Florence Road-Lathrop Invasive Control Determination-2019wpaform1.doc Page 1 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 1- Request for Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town A. General Information Important: When filling out forms on the computer, use only the tab key to move your cursor - do not use the return key. 1. Applicant: Land Conservation Committee of Lathrop Communities Inc. Name E-Mail Address 100 Bassett Brook Rd. Mailing Address Easthampton City/Town MA State 01027 Zip Code Phone Number Fax Number (if applicable) 2. Representative (if any): Firm Barbara Walvoord Contact Name walvoord@nd.edu E-Mail Address 45 Huckleberry Lane Mailing Address Easthampton City/Town MA State 01027 Zip Code 413-203-5086 Phone Number Fax Number (if applicable) B. Determinations 1. I request the Northampton Conservation Commission make the following determination(s). Check any that apply: a. whether the area depicted on plan(s) and/or map(s) referenced below is an area subject to jurisdiction of the Wetlands Protection Act. b. whether the boundaries of resource area(s) depicted on plan(s) and/or map(s) referenced below are accurately delineated. c. whether the work depicted on plan(s) referenced below is subject to the Wetlands Protection Act. d. whether the area and/or work depicted on plan(s) referenced below is subject to the jurisdiction of any municipal wetlands ordinance or bylaw of: Name of Municipality e. whether the following scope of alternatives is adequate for work in the Riverfront Area as depicted on referenced plan(s). wpaform1.doc Page 2 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 1- Request for Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town C. Project Description 1. a. Project Location (use maps and plans to identify the location of the area subject to this request): 100 Bassett Brook Rd. Street Address Northampton (official address is Easthampton) City/Town 44 Assessors Map/Plat Number 051 Parcel/Lot Number b. Area Description (use additional paper, if necessary): The project site lies within the city of Northampton, but is part of the Lathrop Easthampton campus, whose official address is 100 Bassett Brook Rd., Easthampton. The project area lies within the 11.2- acre Conservation Restriction land along Bassett Brook and its banks and floodplain, just north of the city line. The city of Northampton holds the CR (Book 08155, p. 57). The CR is identified as CR #25 in Northampton Open Space Plan, 2011-2018, p. 46. The area is forested. The Northampton land is part of a larger Lathrop project to manage invasives all along Bassett Brook, including Lathrop's continguous land along Bassett Brook in the town of Easthampton. c. Plan and/or Map Reference(s): Title Date Habitat Management Plan with map submitted on flash drive and available at Title 3/1/16 Date https://www.dropbox.com/s/etmqc2oj8ked6rw/Land%20Polatin%202016%20 HMP%20Noho%20Easthampton%20rev.pdf?dl=0 Title Date 2. a. Work Description (use additional paper and/or provide plan(s) of work, if necessary): Invasive plant management activities are proposed for this project area. Target species include Japanese stiltgrass, Japanese barberry, oriental bittersweet, wing euonymus, multiflora rose, and bush honeysuckle. Land Stewardship Inc (formerly Polatin Ecological Services), our contractor, will employ targeted herbicide application of sensitive-area-approopriate material using the cut-stem method in combination with mechanical removal and foliar herbicide treatment, as described in the Hatitat Management Plan https://www.dropbox.com/s/etmqc2oj8ked6rw/Land%20Polatin%202016%20HMP%20Noho%20Eastham pton%20rev.pdf?dl=0. The work has been ongoing since 2016. Future work is follow-up to remove re- sprouts and new infestations. wpaform1.doc Page 3 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 1- Request for Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town C. Project Description (cont.) b. Identify provisions of the Wetlands Protection Act or regulations which may exempt the applicant from having to file a Notice of Intent for all or part of the described work (use additional paper, if necessary). 3. a. If this application is a Request for Determination of Scope of Alternatives for work in the Riverfront Area, indicate the one classification below that best describes the project. Single family house on a lot recorded on or before 8/1/96 Single family house on a lot recorded after 8/1/96 Expansion of an existing structure on a lot recorded after 8/1/96 Project, other than a single family house or public project, where the applicant owned the lot before 8/7/96 New agriculture or aquaculture project Public project where funds were appropriated prior to 8/7/96 Project on a lot shown on an approved, definitive subdivision plan where there is a recorded deed restriction limiting total alteration of the Riverfront Area for the entire subdivision Residential subdivision; institutional, industrial, or commercial project Municipal project District, county, state, or federal government project Project required to evaluate off-site alternatives in more than one municipality in an Environmental Impact Report under MEPA or in an alternatives analysis pursuant to an application for a 404 permit from the U.S. Army Corps of Engineers or 401 Water Quality Certification from the Department of Environmental Protection. b. Provide evidence (e.g., record of date subdivision lot was recorded) supporting the classification above (use additional paper and/or attach appropriate documents, if necessary.) wpaform1.doc Page 4 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 1- Request for Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town D. Signatures and Submittal Requirements I hereby certify under the penalties of perjury that the foregoing Request for Determination of Applicability and accompanying plans, documents, and supporting data are true and complete to the best of my knowledge. I further certify that the property owner, if different from the applicant, and the appropriate DEP Regional Office were sent a complete copy of this Request (including all appropriate documentation) simultaneously with the submittal of this Request to the Conservation Commission. Failure by the applicant to send copies in a timely manner may result in dismissal of the Request for Determination of Applicability. Name and address of the property owner: Lathrop Communities, Inc., Thom Wright, Director Name 100 Bassett Brook Dr. Mailing Address Easthampton City/Town MA State 01027 Zip Code Signatures: I also understand that notification of this Request will be placed in a local newspaper at my expense in accordance with Section 10.05(3)(b)(1) of the Wetlands Protection Act regulations. Signature of Applicant Date Signature of Representative (if any) Date Polatin Ecological Services, LLC Habitat Restoration & Management of Natural Areas Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Habitat Management Plan – Northampton, MA March 1, 2016 The Easthampton campus of the Lathrop Retirement Community is comprised of 175 acres of mixed woodlands and open fields. 50 acres of the campus are within the municipal boundaries of the City of Northampton. Of these, 11.2 acres at the west end, including Bassett Brook, are in Conservation Restriction (CR) held by the City of Northampton (Book 08155, P. 57. Conservation Restriction #25 as listed in Northampton Open Space Plan, 2011-2018, p. 46.) Invasive plants occur at varying densities in this section of the property. Target species found include multiflora rose (Rosa multiflora), purple loosestrife (Lythrum salicaria), honeysuckle (Lonicera spp), Japanese barberry (Berberis thunbergii), bittersweet (Celastrus orbiculatus), winged euonymus (Eounymus alatus), and Japanese stiltgrass (Microstegium vimineum). The Lathrop Land Management Committee has secured funding for invasive plant control work along Bassett Brook as it passes through Lathrop property in both Northampton and Easthampton. The 11-acre Northampton CR section is the focus of work detailed in this Habitat Management Plan. A site visit to assess field conditions and collect information on location and density of target species in the 2016 project area was conducted by Nick Cravedi and Joan Deely on March 8, 2016. (Figure 1). The entire project area is located within jurisdictional wetlands, thereby triggering review of the proposed work by the Northampton Conservation Commission (NCC). The Commission’s finding will inform treatment strategies for these areas. We will finalize the proposal once we know that the NCC has approved the projects. If the NCC requires a Notice of Intent then they will issue an Order of Conditions which may change the specifics of the project. Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Figure 1. Lathrop Retirement Community, Easthampton – Northampton CR section, Northampton, MA. Regulatory Guidance PES derives guidance for invasive plant management in Massachusetts Department of Environmental Protection designated Zone II Recharge Areas from the protocols established by the Right Of Way (ROW) citations included in Appendix A and B. These protocols specify that limited herbicide use is acceptable within designated areas (highlighted in light green on the chart), and that herbicides designated as sensitive materials (333CMR 11.04 (1)(d)) may be applied (Appendix C and D). No herbicide use is permitted within 10’ of open water. In these areas, hand work is the only method allowed. Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Invasive Plant Management Methods Invasive plant control methods will include the following methods: Cut stem treatment Cut stem treatments (CST) treatment is a highly selective method that prevents re- sprouting of the targeted plants, thereby reducing the need for subsequent retreatments. This method is used where maximum control is desired, reduction of the visual impact of vegetation management treatments is required, and/or reduction of potential adverse impacts to desirable vegetation is necessary. CST involves mechanical cutting of the target species followed by herbicide application to the phloem and cambium tissue of the stumps (Figure 2). The CST mixture is diluted in either water or in a non-freezing agent and is applied to freshly cut stumps of woody shrubs and vines. Application equipment includes hand-held bottles fitted with replaceable foam tips that release herbicide only when pressure is applied to freshly cut stumps. This method eliminates off-target damage while ensuring very targeted applications of herbicide. CST may be used at any time of the year provided snow depths do not prevent cutting the stumps below three inches in height. It is not recommended for use during spring sap flow, or during moderate to heavy rains. The method is not practical in areas of moderate to heavy stem densities. Figure 2. Cut stump treatment application. CST is most effective for invasive shrubs that are >6’ tall and/or with stems > 1” diameter. We will use the wetland-appropriate herbicide Rodeo® (glyphosate --- EPA Reg. No. 62719-324) at a mixture of 50% mixed with water 10’-100’ from surface water. Herbicide will be applied directly to the cut stems. Treated bittersweet that have grown into trees will not be pulled down, as this can damage tree limbs and branches. Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Foliar Treatment For a foliar application, invasive shrubs <6’ tall and/or with stems < 1” diameter and low- growing bittersweet vines will be treated using the ultra-low-volume Thinvert application system. The herbicide will be sensitive area –approved glyphosate (EPA # 62719-324) The Thinvert method allows for targeted application of herbicide, and minimizes the risk of drift. More information about this system may be found at http://www.arborchem.com/library/THINVERT_Nov-Dec2014_UAN.pdf. Polatin Ecological Services (PES) proposes the following management sequence for invasive plant treatment at the Lathrop Community east campus CR land that lies within the City of Northampton: 2016 Task 1. Cut stem treatments (2016): Cut stem treatment of woody invasives. Woody debris generated by this process will be piled on-site to create habitat. Task 2. Foliar herbicide application. Foliar treat woody invasives throughout the area. 2017 Task 3. Foliar herbicide application (June 2017): Follow-up foliar treatments. Task 4. Foliar herbicide application (August 2017): Follow-up foliar treatments. 2018 Task 5. Follow-up treatment (June 2016): Follow-up foliar treatment. Success Criteria Objective: 95% invasive plant control resulting from 2016 & 2017 series of treatments and 99% resulting from 2018 follow-up methods. We will establish several photo monitoring plots prior to management work and will monitor the results of treatments each year over the course of the project. Our work is guaranteed to meet the stated success criteria. Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Maintenance & Stewardship Early Detection Rapid Response Use of Volunteers .Invasive plant management is a serious commitment and will need to be ongoing in order to protect your investment in management. To keep invasive plants out of the area for the long term it will be necessary to monitor the area by scouting for new patches and individual plants even after three years of treatment. This scouting procedure will provide early detection of existing and new invasive plant species. Having an Early Detection Rapid Response Plan in place by 2016 will be integral to the project’s long-term success. Volunteers can be used effectively during the stewardship phase of this project. Field training of interested volunteers can develop informed and enthusiastic land stewards well-versed in invasive plant identification (currently listed invasive plants per Massachusetts Invasive Plant Advisory Group and early detection species per Invasive Plant Atlas of New England) and low-tech management techniques. Trained volunteers can help locate new patches of invasive plants as they develop and the appropriate response can be quickly organized. Options for managing invasive plants after the initial three years usually consist of hand pulling, targeted herbicide application, and/or repeated cutting. Ideally, arrangements can be made for continuous stewardship of the property on an annual basis. PES is willing to help you plan for land stewardship in the future. Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 APPENDIX A. Right of Way Sensitive Area Identification Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 APPENDIX B. Table of Sensitive Area Restrictions (ROW) Sensitive Areas are defined as Limited Spray Area and No Spray Areas within rights-of- way in which public health, environmental, or agricultural concerns warrant special protection to further minimize risks of unreasonable adverse effects of herbicides: Sensitive Area No Spray Zone limited Use Zone Where Identified Wetland and Water Over Wetlands Within 10 feet (unless provisions of 333 CMR 11.04(4)© are followed) 10-100 feet; 12 months must elapse between applications' Selective low pressure, using foliar techniques or basal or cut- stump applications. YOP Maps and identify on site Certified Vernal Pool Within 10 feet.10 feet to the outer boundary of any Certified Vernal Pool Habitat;12 months must elapse between applications; Selective low pressure, using foliar techniques or basal or cut- stump applications YOP Maps and identify on site Public Ground Water Supply Within 400 feet (Zone I) Zone II or IWPA (Primary Recharge Area); 24 months must elapse between applications; Selective low pressure, using foliar techniques or basal or cut- stump applications YOP Maps Public Surface Water Supply Within 100 feet of any Class A public surface water source 100 feet to the outer boundary of the Zone A; 24 months must elapse between application; Selective low pressure, using foliar techniques or basal or cut-stump applications. YOP Maps Within 10 feet of any tributary or associated surface water body located outside of the Zone A 10 feet to the outer boundary of the Zone A; 24 months must elapse between applications; Selective low pressure, using foliar techniques of basal or cut- stump applications. 24 months must elapse between applications; Selective low pressure, using foliar techniques or basal or cut-stump applicationsWithin 100 feet of any tributary or associated surface water body located within the Zone A of a Class A public surface water source Within a lateral distance of 100 feet for 400 feet upstream of any Class B Drinking Water Intake Within a lateral distance of between 100 -200 feet for 400 feet upstream of intake; 24 months must elapse between applications; Selective low pressure, using foliar techniques or basal or cut-stump applications Sensitive Area No Spray Zone limited Use Zone Where Identified Private Water Supply Within 50 feet 50 – 100 feet; 24 months must elapse between applications; Selective low pressure, using foliar techniques or basal or cut- stump applications In YOP well list and identify on site Surface Waters Within 10 feet from mean annual high-water line 10 feet from the mean annual high water line and the outer boundary of the Riverfront Area; 12 months must elapse between applications; Selective low pressure, using foliar techniques or basal or cut-stump applications YOP Maps and identify on site Agricultural and Inhabited Areas N/A 0 – 100 feet 12 months must elapse between application; Selective low pressure, using foliar techniques or basal or cut-stump applications. YOP Maps and Identify on site State-listed Species Habitat No application within habitat area except in accordance with a Yearly Operational Plan approved in writing by the Division of Fisheries and Wildlife YOP Maps Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 APPENDIX C. Rights-of-Way Sensitive Area Materials List (MA DAR) Contact: Hotze Wijnja (SAML) at hotze.wijnja@state.ma.us - 617-626-1771 Herbicide EPA Reg # Active Ingredient Method of Application Rate Product on Sensitive Areas Material List? Restricted Entry Interval (REI) ACCORD CONCENTRATE 62719- 324 Glyphosate Foliar 2-5% YES 4 hours RODEO 62719- 324 Glyphosate CST Foliar 25% 1-3% YES 4 hours GARLON 4 ULTRA Reg. No. 62719‐ 40 Triclopyr CST Foliar 20% 2-5% YES 12 hours POLARIS 228-534 Imazapyr Foliar 0.5-1% YES 12 hours ESCORT XP 352-439 Metsulfuron methyl 4 oz./per 100 gallons YES 4 hours Surfactants CIDE KICK II (wetland surfactant) NA d-limonene Foliar 0.25- 0.5% NA NA KINGPIN (upland surfactant) NA Methylated seed oil Foliar 0.25- 0.5% NA NA Diluent Arborchem Non Petroleum Diluent (upland) NA Methylated seed oil CST 80% NA NA Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 APPENDIX D. Sensitive Area Materials List Contact: Hotze Wijnja, Hotze.Wijnja@state.ma.us, 617-626-1771 Active Ingredient Use Restrictions Product Names (EPA #) Registrant Glyphosate Lowest Labeled Rate for all Glyphosate products Round Up Pro (524-475) Monsanto Glypro-Plus (62719-322) Accord Concentrate or Rodeo (62719-324) Dow AgroSciences Aquaneat Aquatic Herbicide (228-365)Nu Farm Americas While Accord Concentrate, Rodeo, Glyphosate VMF and Aquaneat all have aquatic uses, approval for their use as sensitive materials does NOT mean that they can be used for aquatic weed control, or directly applied to water, as part of a rights of way management program. Products are subject to the no-spray and limited spray provisions of 333 CMR 11.04. Metsulfuron Methyl Lowest Labeled Rate for all Metsulfuron Methyl Products* Escort XP (352-439) EI Dupont Patriot Selective Herbicide, (228-391) Nu Farm Americas Sulfometuron Methyl Lowest Labeled Rate for all Sulfometuron-Methyl Products* Oust XP (352-601) EI Dupont Spyder Selective Herbicide (228-408) Nu Farm Americas Metsulfuron Methyl Sulfometuron Methyl Lowest Labeled Rate* Oust Extra (352-622) EI Dupont Ammonium Salt of Fosamine Lowest Labeled Rate* Krenite S (352-395) EI Dupont Krenite S (42750-247) Albaugh, Inc. Imazapyr 3 pints/acre every 3rd year OR 2 pints/acre every other year for all Imazapyr Products Arsenal (241-346) Arsenal Powerline (241-431) Arsenal Railroad Herbicide (241-273) BASF Polaris Herbicide (228- 534) Nu Farm Americas Triclopyr, Butoxy Ethyl Garlon 4 (62719-40) Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 Ester The lowest of the following rates: 1. Between 10 feet and 50 feet of the resource: Lowest labeled rate* or 0.5 pints per acre 2. Between 50 feet and the boundary of the limited spray zone: Lowest labeled rate* or 3 pints per acre Dow AgroSciences Garlon 4 Ultra (62719-527) Dow AgroSciences Paclobutrazol Lowest Labeled Rate* Cambistat (74779-3) Rainbow Tree care * Lowest labeled rate the minimum labeled rate of the pesticide product for the appropriate site, pest and application method Disclaimer The Massachusetts Department of Agricultural Resources (MDAR) makes no endorsement of any companies, organizations, persons, products, trade or brand names referenced in this Rights of Way Sensitive Area Materials List (“the list”). Active Ingredients on the list are reviewed pursuant to a Cooperative Agreement between MDAR and the Massachusetts Department of Environmental Protection. Only environmental fate and toxicological data, including eco-toxicological data, are reviewed when evaluating active ingredients suitability for inclusion on the list. Inclusion on the list does not represent any endorsement by MDAR as to the efficacy of the active ingredient for rights-of-way vegetation management. Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 APPENDIX E. Surfactants and Carriers Surfactant CHEMSURF 90 • A non-ionic Surfactant added to herbicides used for foliar applications. • Principle Functioning Agents: Alkylarylpolyoxykane Ether, Glycol and Free Fatty Acids: 90% Constituents Ineffective as a Spray Adjuvant: 10% Basal Oil Arborchem Low Odor Basal Oil • Aliphatic and cyclic based natural petroleum products and non-ionic emulsifiers – Aliphatic and Paraffinic Petroleum Distillates Habitat Management Plan Bassett Brook Invasive Plant Control Lathrop Retirement Community – Northampton CR Land Easthampton, MA Polatin Ecological Services, LLC 413-367-5292 PO Box 511 732-474-9757 (fax) Turners Falls, Massachusetts 01376 APPENDIX F. OPERATIONAL GUIDELINES FOR HERBICIDE APPLICATORS All crew applicators must hold at a minimum a Massachusetts Pesticide Applicator License issued by the Department of Agricultural Resources. In addition to the applicable rules and regulations, applicators will adhere to the following operational guidelines: Weather Herbicide application will be restricted during certain adverse weather conditions, such as rain or wind. Scheduling of spray operations will be attentive to forecast conditions: Herbicide applications will not be made during periods of moderate or heavy rainfall. Foliar applications are effective in light mist situations. However, any measurable rainfall that creates leaf runoff will wash the herbicide off the target plant. If foliar applications are interrupted by unexpected rainfall, the treatment will not resume until the rain ends and active leaf runoff has ceased. Excessive wind can create drift during foliage applications causing damage to desirable vegetation. To minimize off target drift, the applicator will comply with the following restrictions: • The applicator will monitor wind conditions to insure that there is no significant movement of the herbicide. If the applicator can see the herbicide moving off target, the application will immediately stop until the wind has subsided enough to permit further application. • All herbicide solutions to be used for a foliar application will contain anti-drift agents. Anti-drift agents will be added to the foliage herbicide solutions as per the anti-drift agent label. In moderate wind conditions, as per label recommendations, more anti-drift agent may be added, at the discretion of the applicator to control increased drift. • Foliar treatments will not be made to target vegetation that exceeds approximately twelve feet in height. • Equipment Calibration – Low-pressure foliar application equipment will be calibrated to maintain pressure not exceeding 60 pounds per square inch at the nozzle. The equipment will be calibrated and a Spray Controller will be used to deliver a consistent flow rate of approximately 40 gallons/Acre. For boom applications the boom will be kept as low as possible to reduce the drift hazard and a drift control additive will be included in the spray formulation to increase droplet size and give a uniform distribution of spray material.