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20

EXHIBIT 10 14-69-C

Ground Potential Rise Explained

Back Ground Information
For High Voltage Transmission Towers

Includes Information on Soil Resistivity Testing

Release Date:
September 1, 2010
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Ground Potential Rise

This section will present an introduction to the information used in conducting a
GPR study and why it is gathered.

his report provides relevant back ground information regarding GPR Studies and Soil
TResistivity testing that is applicable to all Ground Potential Rise Analyses.

When conducting an Advanced GPR Study’s one can utilize the MALZ
software module in the CDEGS software program to simulate the
effects of a fault on the buried component of the grounding system,
by injecting the current directly into the tower footings, and
calculating the voltage drop / current leakage across the conductor
segments. Electrical data is typically provided by the power
company.

Safety in the work place is mandatory near the world over, and electrical hazards are no
exception. The effects of electrical faults and the ground potential rise they can create have
been known since the earliest days of electrical invention. The ability of these electrical faults
and/or lightning strikes to generate voltages with enough energy to fibrillate the human heart
are well understood, the primary concerns being current pacing through the hands to the feet
(Touch Voltage), and current flowing from one foot to the other foot (Step Voltage).

Federal regulations (29 CFR 1910.269) mandate that all known electrical hazards be eliminated
in the work place. Appendix C specifically states that Ground Potential Rise (GPR) analysis are
conducted and Step & Touch Voltage hazards be eliminated from high-voltage work
environments. Transmission lines (high-voltage towers), substations, and certain transformers
are the most common places that require these types of studies. Transmission lines (high-
voltage towers) are often exempt as they are not considered work places, unless cellular
communication equipment is installed on the tower; it is then considered a work place and must
comply with 29 CFR 1910.269.

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GPR Information

General Information about GPR Studies

The purpose of conducting a Ground Potential Rise (GPR) Study is to determine what the effects
electrical faults, lightning strikes, and/or short circuits will have on personnel and equipment
within the fault area. In the event of a ground fault, understanding what the clearing time and
the dissipation of the high-voltage event will be, allows for the safest and most cost effective
grounding system design possible, without over engineering allowing you to stay within
budgetary constraints.

Ground Potential Rise

Ground Potential Rise (as defined in IEEE Std 367) is the product of
a ground electrode impedance, referenced to remote earth, and
the current that flows through that electrode impedance.
GPR studies use a series of calculations to determine Step and
Touch Voltages in accordance with specific standards. These
studies also help to determine grid “hot spots” enabling the
engineer to understand the behavior of grounding systems and to
modify the designs accordingly.

Copper wire communications cables within high voltage environments (substations, power
plants, transmission towers) can be exposed to thousands of volts during a power system fault.
In that instant, the entire site will experience a ground potential rise, and dangerous potential
differences can occur between the power station and the remote (theoretically “zero”) ground of
the telecommunication cable (central office). Any voltage difference will trigger a current flow,
which as the potentials equalize, may have destructive consequences for personnel or sensitive
electronics.

Each year, GPR electrical damage is costing the industry millions of dollars, yet few engineers or
their managers are even aware of the phenomenon.

Adherence to industry practices and standards, such as IEEE Standard 80, Standard 487,
Standard 367, and Standard 1590, is highly recommended.

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GPR Information

Benefits of Advanced GPR Studies

An Advanced Ground Potential Rise (GPR) Study provides a comprehensive examination of the
effects an electrical fault will have on a grounding system. This enhanced study provides the
ability to “inject” current directly into specific conductors and to calculate the voltage drop
across the grounding network as the current flows through and out of the system.

MALZ Software Module – Frequency Domain Grounding

Analysis
One can use MALZ it is one of the most powerful software
modules in the CDEGS program. It analyzes the frequency
domain performance of buried conductor networks and calculates
the following quantities: earth and conductor potentials,
longitudinal and leakage current distribution in the conductors, as
well as magnetic fields in the air. This powerful grounding
package is the ideal tool whenever coated conductors such as
pipelines need to be modeled and / or if the metallic conductors
can no longer be approximated as equipotential structures.
Additionally, MALZ calculates in the effects of the frequency of the fault (60Hz) on the
grounding system.

For a common GPR study, equipotential calculations are typically used to determine the effect of
the fault on the grounding system. In other words, once the voltage rise has been figured out,
that voltage number is locked in place and used as a constant across every segment of the
grounding grid. In some cases, such as when in highly resistive soils and/or dealing with a very
small grounding grids, the use of equipotential calculations is a reasonable assumption.

It should be noted however that equipotential calculations can have significant disadvantages.
The purpose of the grounding system, specifically of the buried conductor or ground rod, is to
dissipate electricity into the earth, or to “drop the voltage” over its length. This is sometimes
referred to as ‘leakage’ or even leakage resistance. An Advanced GPR calculates the voltage
drop across every segment of the grounding system, providing greatly enhanced accuracy. This
is especially true for Step & Touch Calculations where common GPR studies tend to show
hazardous voltages at the corners of grounding grids, or at the ends of conductor extensions.
Another prime advantage of an Advanced GPR is Current Injection. Obviously, if a fault or
lightning strike were to occur on one side of a building or grounding system, current will flow to
the other side, dissipating (leaking) in to the surrounding soil as it goes, creating a Ground
Potential Difference (GPD). With a common GPR, every conductor and segment is at the same
potential, so you cannot calculate what happens if one side of a grid takes a fault.

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GPR Information

Ground Potential Rise (GPR) is the transient over voltage that enters the earth in the form of
current causing differences of potential to form across the surface of the earth as the earth
absorbs electricity in proportion to the level of conductivity of the earth and the distance from
the entry point. Those differences in potential, not the actual voltage, are what is hazardous to
personnel and equipment. It is the electrical engineers job to eliminate those differences in
potential making equipment that has faulted and the area surrounding the entry point safe.

Electricity is “free” electrons in motion looking for a path to the earth.

We control these “free” electrons by creating conduits to carry the
electricity for our use. As we do this we run the risk of transient over
voltage occurring which is hazardous to personnel and equipment.
A transient over voltage is the temporary over load of “free
electrons”. Transient over voltages occur all the time.

When transient over voltage occurs (e.g. lightning strike, equipment fault, operation of a
switching device), electricity (or free electrons) is absorbed into the earth. These “free” electrons
will always take the path of least resistance to earth. Depending upon the composition of the
earth, these electrons will either be absorbed or they will continue on looking for materials to
bond with creating an unsafe environment for personnel and equipment nearby.

The purpose of a GPR study is to determine the composition of the earth and thereby
determining the amount of electricity that will be absorbed into the earth and how much excess
electricity will be left in the earth causing potential harm to personnel. We will also determine
how long this excess electricity will remain in the earth and the distance or footprint the
electricity will make (i.e. what is the size of the pool of electricity surrounding the transient over
voltage strike point).

Electricity always seeks the quickest, easiest path to ground. Electrical professionals’ preplan
electrical grounding designs to ensure that any stray electricity is returned to earth safely.

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GPR Information

If, however, electricity is released onto the ground, the electricity will fan out from the point of
contact. There is a rippling effect like dropping a pebble into calm water. In the pool of water,
the wave created at the point of contact gets smaller as it rings out.

Similarly, in this pool of electricity, the

energy is at full system voltage at the point
of ground contact, but as you move away
from the contact point, the voltage drops
progressively. This effect is known as
ground gradient. The ground gradient, or
voltage drop, creates two problems known
as step potential and touch potential.

Assume that a live downed wire is touching

the ground and has created a pool of electricity. If you were to place one foot near the point of
ground contact (at x voltage) and your other foot a step away (at y voltage), the difference in
voltage would cause electricity to flow through your body.

This effect is step potential. Similarly, electricity would flow through your body if you were to
place your hand on an energized source, while your feet were at some distance from the source.
The difference in voltage in this case is referred to as touch potential. If you touch an energized
wire or another energized object and the ground at the same time, you may be killed or injured.

Personnel can either be harmed when physically touching the equipment that has faulted or by
standing on the earth that the electricity has just entered. Unfortunately, the grounding systems
that cure “step” hazards and “touch” hazards are very different.

A Ground Potential Rise (GPR) Study determines what the effects electrical faults and other
transient over voltages will have on personnel and equipment within the fault area.

For further understanding of the safety requirements, please refer to 29 CFR 1910.269

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GPR Information

Rules of Thumb

There are some general “rules of thumb” that should be addressed in regards to understanding
proper grounding design and the mitigation of hazardous voltages.

Soil conditions determine practically everything in regards to electrical grounding. High-

resistivity soils are a problem in virtually all scenarios. The more the soil impedes the flow of
electricity (i.e. resistance), the greater the voltages that can form in the soil and the more
difficult it is to clear a fault, man-made or natural (i.e. lightning).

When designing a grounding plan, the methods used in the reduction of step & touch
potentials can be at odds with each other:

• For step potential reduction, it is typically desirable to move the current away from
personnel by placing grounding conductors into the earth as deep as possible.
• For touch potential reduction, it is typically desirable to keep the ground conductors as
close to the feet as possible, thereby reducing the possibility of any difference in
potential between the hands and feet of personnel.
• Step potentials are a concern across the entire compound (and beyond), as these
hazardous voltages can form at great distances from the fault location. As electrical
fault currents enter the earth, the electricity will travel through the grounding system
and out into the surrounding soil. As this electricity propagates across the surface of
the earth, personnel may be standing or ‘stepping’ in the way of the electrical surge,
potentially injuring personnel. The difference in potential between the right foot and
left foot of a person must be taken into account. Obviously, the further apart the two
feet are, the greater the difference in potential can become, and thus a conservative
number of one-meter (3.28-ft) is used as the maximum walk/run stride distance of a
person.
• Touch potentials are only a concern for the distance that a person can ‘touch’ an object.
In other words, since a person can only stretch their arms and ‘reach’ an object that is
one-meter (3.28-ft) away, touch potential calculations are only relevant from the a given
object to the reach distance.

Balancing the impact between what is good grounding design for reducing step potentials,
versus what is good for touch potentials can be difficult. Often, a grounding design that
reduces step potentials can adversely impact the touch potentials. For example, moving the
ground ring down to a depth of 3-ft into the earth, may eliminate step voltages, however the
added depth also creates a greater difference in potential between the hands and the feet,
causing a sharp increase in touch voltage.

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Soil Resistivity

Soil Resistivity Measurements

This section will present information relevant to the collection of soil resistivity data f or high-voltage
environments and GPR sites.

Soil Resistivity
The Wenner 4-Point Test Method was used to gather the data
required in modeling the soil resistivity profile for the site. This test
involves passing a known current through the earth and measuring
the differential voltage drop across the tested earth. Various depths
can be tested based upon probe spacing providing a complete profile
of the soil down through any required depth.

Soil tests for GPR sites should be conducted using the Wenner 4-Point resistivity test method.
Soil measurements are often conducted in open fields near the site. Test spacing’s from 6-
inches to 90-ft (270-ft traverse) or longer are typical. All tests should be performed on the site
using 6-inch long current probes, and 6-inch long potential probes. Spacing’s under 2.5-ft
should be taken using 4-inch long probes.

The results of the soil resistivity measurements should be modeled with a multi-layer configuration
one can use the RESAP analysis program, which is a software module from the main CDEGS
grounding design program.

C1 I C2
P1 P2
V
Do S Di S S
Wenner 4-Pin Soil Resistivity Arrangement

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Soil Resistivity

Frost Line and Comparison to Geotechnical Reports

It is important to note, that when the soil freezes, a 10x increase in soil resistivity can occur.
Other indicators such as recent rainfall or snow are important to note when determining the
effects weather will have on the soil model; for example if the weather conditions were below
freezing on the day of the test, and the ground itself was not frozen.

If the site is in a freezing climate, it is recommended that an additional soil layer be added and
set to 10X the ohm meters of the current top layer in the soil model when considering the
effects of frost line to the site.

Wenner 4-Pin Method

In order to determine an equivalent soil resistivity model for a given site, soil resistivity
measurements are performed using one of several methods available. Typically one of the two
four-pin arrangements (as mentioned below) is chosen to perform the measurements as they
are the most reliable and accurate, and therefore are recommended in IEEE Standard 81-1986
(“IEEE Guide for Measuring Earth Resistively, Ground Impedance, and Earth System Potentials of
a Ground System”). The Wenner arrangement and the Schlumberger-Palmer arrangement are
the two most common four-pin arrangements.

The four-pin methods involve the use of two current pins, one to inject current into the ground
and the other one to collect the current. This current is measured by an ammeter as the current
is injected. Two voltage probes are placed in line with the current probes, in between the
injection and collection probes. A voltmeter is placed in between the probes to measure the
resulting voltage.

The arrangement of the four probes in line with each other varies between methods. The
Wenner arrangement uses equal spacing in between all probes. The Schlumberger-Palmer
arrangement uses fixed potential probes but unequal current probe spacing.

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Soil Resistivity

The distance between the probes used in both methods is varied in order to determine different
layers of soil resistivity. The probes should not be placed very deep in the soil (particularly for
shorter spacing’s since the probe could distort the readings). A typical recommendation is no
greater than 1/20 of the spacing of the probes. When the current probes are placed into the
soil and energized, they will act as a point source in the earth. The result is a hemispherical
energization as the current spreads out as it flows through the different layers of the earth. In
order to determine the top layer by taking measurements with probes close together, the
majority of the voltage difference will occur near the surface of the earth, resulting in an
effective resistance to characterize this top layer. Increasing the probe spacing increases the
overall length of the path that is detected.

Measurements are taken over a long traverse with increasing spacing’s to obtain the data
necessary to determine the resistivity of each layer of soil. Typically it is recommended that
these measurements determine the resistivity of the soil to a depth equal to the maximum
dimension of the substation or grounded facility. This depth of soil will have an effect on the
performance and resistance of the grounding system and therefore it is critical to know the full
extent of this soil.

Wenner 4-Pin Soil Resistivity Test

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Soil Resistivity

Test Equipment
The instrument selection is important for soil resistivity measurements. One of the most
recommended meters is the Sting R1 or “MiniSting” by Advanced Geosciences, or similar model
be used. This Earth Resistivity and IP (Induced Polarization) meter is highly respected in the
geological industry and is one of only two (2) brands approved for use by Safe Engineering
Services & Technologies Ltd., the manufacturers of the CDEGS computer modeling software.
This meter requires an external car-battery for its operation, as it generates an 800 Volt p-p DC
signal, with current levels as high as 500mA. This kind of power is not to be treated lightly, and
requires special precautions to be taken in the field to ensure personnel safety.

In addition to the impressive power supply, this

meter has one of the most advanced electronic
packages available on the market. The system’s
transmitter and receiver have been proven to
provide the most reliable and accurate readings
in even the most severe soil conditions. The
signal processing and noise suppression systems
are able to filter out stray voltages and unwanted
signal noise. Numerous sites are prone to these
excessive interference’s from energized power
lines or other energized stations. The use of this system ensures that the received signal is the
same as the one transmitted.

The Sting Resistivity Meter (manufactured by Advanced Geosciences Inc.) provides

measurements in ohms as a ratio of the measured voltage to the injected current. A summary
of the resistance measurements performed for each measurement traverse is included in the
following sections. The measurements for this site were performed at 0 Hz (DC), a frequency
that is not a harmonic of the power system and not an interference concern at the site as it may
be subject to a large amount of 60 Hertz (or harmonic frequencies of 60 Hertz) interference.
The Sting device uses higher power to avoid the influences of interference and transmits at DC
frequencies to mitigate any errors from this situation.

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Soil Resistivity

Calculating Resistivity
After collecting field measurements of apparent resistances for various probe spacing’s,
equivalent apparent resistivities can be calculated using a simple formula. By injecting a current
(I) between the two current electrodes, C1 and C2, in the earth and then by measuring the
voltage ∆V between the two adjacent potential electrodes, P1 and P2, as indicated in the figures
below. The spacing’s between C1 and P1, between P1 and P2 and between P2 and C2 are a1, a2,
and a3, respectively. Depending upon the relations between a, and a, one could have Wenner,
Schlumberger, Unipolar, dipole and/or a general electrode configuration. The injected current
should be at low frequency to reduce the inductive coupling between the leads of the circuit.

The equation to convert apparent resistance to apparent resistivity is:

Additional information on soil resistivity calculations and equations is available upon request.

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Soil Resistivity

Soil Model Development

Using the apparent resistivities for each probe spacing (which coordinates with an equivalent
depth of the measurement), a soil model can be calculated using graphical methods or
advanced computational methods using computer software. Further details on developing a
soil model graphically can be found in IEEE Standard 80-2000, “IEEE Guide for Safety in AC
Substation Grounding.”

y The soil models can be developed using the

RESAP module of SES’s (Safe Engineering
x
Software) CDEGS (Current Distribution,
Depth

Top
Thickness Central Electromagnetic Fields, Grounding and Soil
Structure Analysis) software. The RESAP module
Bottom

z
uses the probe spacing’s, probe depths, and
apparent resistance measurements as input and
develops an optimized equivalent multi-layer soil model from this datum.

When the individual test point apparent resistivities are combined into an equivalent soil model
with a finite number of layers, some error is introduced. This combines with errors in the
measurements (distance between probes, equipment errors, etc.) to produce an overall model.
Typical practice indicates that when possible the RMS error should be kept to under 10%,
although errors as high as 20% are acceptable in certain circumstances (such as limiting to a two
layer model).

When performing a grounding analysis the number of soil layers used in the model can have an
impact on the results of the study. An equivalent single layer soil model can produce largely
inaccurate results, and therefore is rarely used. At a minimum an equivalent two layer soil
model should be produced. Some software used for grounding system analysis is limited to two
layers, and therefore such a model must be used, even if not as accurate. The CDEGS software
will allow over 20 layers for a soil model, which could produce a much more accurate
representation of a grounding system’s performance, reducing the RMS error of the soil model.
However, as additional layers are considered, computation time increases significantly.
Therefore a compromise must be met at some point and a certain number of layers must be
determined for a final model.

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Specifications

Reference Specifications
The following electrical specifications should be standard for use at GPR sites:
• Copper-clad ground rods shall be a minimum 5/8-in diameter by 10-ft in length.
• All grounding conductors shall be a minimum 2/0 seven (7) stranded bare copper wire.
Larger conductor sizes may be used unless otherwise noted.
• The exterior ground ring is to be connected to all gateposts, corner posts and every other
fence post; 4/0 flexible copper jumper must be connected from the gate to the gate posts.
• All conductor connections shall be exothermically welded or connected by other approved
permanent and irreversible bonding method.
• Routing of conductors should avoid the use of metallic conduits and sharp bends.
• All ground conductors shall be bare copper wire buried in direct contact with the native soil.
Use of concrete around the conductors is highly discouraged.
• New ground grid must be connected any adjacent substation ground grid in at least two (2)
locations.

The following table shows the ultimate current carrying capabilities for 2/0 AWG copper wire for a
frequency of 60 Hz, current in kilo-amperes:

2/0 AWG 6 cycles 15 cycles 30 cycles 45 cycles 60 cycles

Cable (100 ms) (250 ms) (500 ms) (750 ms) (1 s)
X/R = 20 51 kA 36 kA 26 kA 22 kA 19 kA
X/R = 10 56 kA 38 kA 27 kA 22 kA 19 kA
X/R = 0 62 kA 39 kA 28 kA 22 kA 19 kA
Table 2: 2/0 AWG Cable Capacity

The following table shows the ultimate current carrying capabilities for 4/0 AWG copper wire for
a frequency of 60 Hz, current in kilo-amperes:

4/0 AWG 6 cycles 15 cycles 30 cycles 45 cycles 60 cycles

Cable (100 ms) (250 ms) (500 ms) (750 ms) (1 s)
X/R = 20 81 kA 57 kA 42 kA 35 kA 30 kA
X/R = 10 89 kA 60 kA 43 kA 36 kA 31 kA
X/R = 0 99 kA 63 kA 44 kA 36 kA 31 kA
Table 3: 4/0 AWG Cable Capacity

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300 Volt Peak Line

Copper-Wire / Telecommunications Protection in

High-Voltage Environments

This section will present relevant drawings that have been based on the templates provided, with mark-ups
demonstrating relevant information presented in the study.

Telecommunications Protection
Copper wire communications cables within high voltage environments (substations, power plants,
transmission towers) can be exposed to thousands of volts during a power system fault. In that instant, the
entire site will experience a ground potential rise, and dangerous potential differences can occur between the
power station and the remote (theoretically “zero”) ground of the telecommunication cable (central office).
Any voltage difference will trigger a current flow, which as the potentials equalize, may have destructive
consequences for personnel or sensitive electronics.

Ground Potential Rise

Ground Potential Rise (as defined in IEEE Std. 367, 487 & 1590) is
the product of a ground electrode impedance, referenced to remote
earth, and the current that flows through that electrode impedance.
GPR studies use a series of calculations to determine the scalar
potentials that will be found around the facility, enabling the engineer
to determine how far away the copper-fiber junction (CFJ) needs to
be placed.

Voltage Zones
In general, protecting the telecommunications system involves moving unprotected copper-wires outside of
the 212-volt RMS (or 300 volt peak) zone. Any copper-wires connected to the telecommunications system
inside that zone, requires additional protections as outlined in IEEE Standards 487 & 1590. In IEEE Std.
487, three (3) Voltage Levels have been identified:

• Level I:: 300 Volts peak

• Level II:: 301 to 1,000 Volts peak
• Level III: Higher than 1,000 Volts peak

IEEE Std. 1590 is primarily concerned with the placement of the Copper-Fiber Junction (CFJ). This
standard requires that the CFJ be placed outside of the 300-Volt peak zone or a minimum of 150-meters
from the station, whichever is less.

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Coverings

Ground Coverings

This section will present any additional relevant materials in regards to highly
resistive ground coverings that will help to provide additional layers of safety for
personnel.

Ground Coverings
Ground coverings can be used for a variety of reasons, from aesthetic, to water drainage, to
electrical safety. Crushed rock is one of the most commonly used ground coverings.

Crushed Rock
The most effective way to prevent weeds from establishing is by
maintaining a 6-inch layer of clean, crushed rock (similar to gravel) in and
around hazardous areas. Crushed rock surfaces should also extend 6-ft
outside the facility fence line to minimize the drift of seeds from outside,
and to maintain public safety by reducing electrical exposure. Crushed
rock has many features that contribute to electrical and engineering
safety. In particular, it has a high level of electrical Resistivity (3,000 ohm-
m when wet), which means it does not readily conduct electricity, thereby reducing the risk of
electrocution over the ground grid. Additionally, crushed rock retards the evaporation of
moisture from the underlying soil, thus lowering the resistivity of the soil and improving its
ability to conduct the fault or lightning current into the ground and away from the surface.
Other functions and advantages of crushed rock are:

• It allows rapid surface drainage.

• It is economical and readily available.
• 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.
• It helps control dust.
• It provides a finished, aesthetically pleasing surface.
• It greatly impedes the establishment of weeds.

Over time, the resistivity and effectiveness of crushed rock surfaces is reduced due to
construction activity, traffic, and organic matter build-up that encourages establishment of
weeds. Therefore, for optimal safety and weed control, crushed rock surfaces are occasionally
replenished.

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Coverings

Crushed Rock over Geotextile

The effectiveness of crushed rock for excluding weeds can be enhanced with a geotextile layer
close to fence lines and in areas where herbicides cannot be used. Geotextile is a porous,
polypropylene fabric that is laid underneath the crushed rock. It can also be staked to the soil in
areas without crushed rock. Geotextile should not normally be used in drive-able areas because
it may become damaged, or around oil-filled equipment because it will cause the oil to spread
during a spill.

Asphalt and Concrete

Asphalt and concrete can also be used near electrical equipment, but are not as favorable as
crushed rock. As shown in Table 7 of IEEE Std 80-2000, asphalt has 10,000 ohm-m when wet.
Concrete will readily conduct electricity and tends to mimic the resistivity characteristics of the
surrounding soil over time. Both asphalt and concrete are more expensive than crushed rock.

Neither asphalt nor concrete should used around oil-filled equipment because they will cause
the oil to spread in the event of a spill, and asphalt will burn at high temperatures. The use of
asphalt and concrete is generally limited to access roads and storage areas inside facilities.

Alternate Surface Materials

Other surfacing materials, such as limestone surfacing and crushed oyster shell have been tested
to see if they exclude weeds more effectively than crushed rock. Limestone has low resistivity,
may impede drainage, is expensive, and is not readily available. Oyster shells are expensive and
have limited application.

Restricting Organic Matter and Seeds

Organic matter and seeds should be kept from entering the facility and contaminating the
crushed rock. This can be done by:

• removing trees (especially deciduous), grass, and shrubs growing close to the facility
fence line to reduce debris deposition inside the facility
• maintaining a 6-ft crushed rock strip outside the fence line (over the ground grid) of
substations to reduce the spread of invasive plants, such as blackberry, horsetail, broom,
and groundsel

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