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The degree of risk doesn’t justify the proposed destruction.

The transmission corridor Eversource wants to widen is already wide and reliable. (Outages are far more likely on smaller distribution lines, not the large transmission lines, which have wide corridors.)

• There have been zero outages on the line that makes up 28 of the project’s 29.3 miles. 

• Even in the historic October 2011 storm, only one tree-caused outage impacted any 345KV line (i.e., the ones that already have wide corridors). That one tree could and should have been selectively cut as part of an annual inspection.

Eversource already keeps the transmission lines reliable, as required by federal standards, and they do it without further clear-cutting.

• Since Eversource already selectively cuts the trees that are “danger trees” (as defined by the North American Energy Reliability Corp. (NERC), the thousands and thousands of additional trees this project targets are not dangers. Cutting them would not increase reliability. 

Corridor width should be evidence-based, with data showing that a corridor of a given width yields enough reduction in outages to merit the environmental drawbacks.

Eversource is self-serving and deceptive when they:

• omit their current, effective selective management practices from their alternatives analysis.

• refuse to consider alternatives except if they apply across the entire project. (For example, it seems feasible to raise two towers that could spare the entire Buffam Falls area, even though not all the project’s towers can be raised.)

• try to redefine danger trees as every single tree that might, if it broke records over the next 40 years, reach the wires, plus all the other nearby trees with mature heights of >30’. 

• try to redefine selective management as eliminating six acres of their project, when real selective management is a well-established practice that they could continue to apply throughout the project.

• Cutting everything all at once is cheaper for Eversource.

• Eversource expresses no intent to pass along the savings. 

• Higher profits for Eversource don’t naturally lead to lower costs for customers. They substantially increased customers’ bills even while their net profits doubled between 2024 and 2025.

• Increasing corporate profits is not adequate justification for moving down the avoid, minimize, mitigate hierarchy.

Secretary Tepper doesn’t live here, and she doesn’t know many of the places that will be destroyed. If an area in your community is at risk, telling her about it could have true impact. Policy makers remember stories more than they remember statistics. It is up to us to paint a picture for Sec. Tepper. 

An example: For one example, here are some points about Buffam Falls:

Eversource started off by claiming they weren’t cutting at all in Buffam Falls. Their maps show that’s a technicality in that the right-of-way is theirs, not the conservation area’s. They absolutely do plan to cut a swath through an area residents consider part of Buffam Falls.

Eversource did eliminate 0.65 or an acre from their plan, but they still propose to clear-cut the historically unstable rock face and all the way down the gorge to the water’s edge on both sides.

Eversource initially justified clear-cutting by saying it was needed to keep the trees from the wires. We pointed out that it’s physically impossible for most trees in this deep gorge to reach the wires. Now they say even if trees can’t reach the wires, they need to clear-cut for “access.”

• • There are no towers or equipment there, so we asked them, “access for what?” They replied that it’s in case a wire spontaneously ruptures and falls onto the trees.

  • That would admittedly be a bad situation, but an unlikely one. Preemptively clear-cutting the whole area would also be a very bad situation for the many of us who cherish it, and a guaranteed one. That’s a bad trade.

  • Even if they did clear-cut, the sheer cliff face and the two rivers would still pose more substantial obstacles to Eversource’s hypothetical access than the trees ever could have. Eversource would need an access plan either way.

  • Eversource should clarify how they’d handle such a situation if they hadn’t clear-cut, and if they had. Given how extraordinary such a situation would be, the difference in the two responses would have to be exceedingly stark to justify destroying an area that means so much to so many.

Buffam Falls is a case in point. The same lack of discretion that Eversource is demonstrating in this area is characteristic of the entire project, which should be scrutinized accordingly.