We have until November 21, 2025 to submit public comments.
Write your own or use the sample below. Write what you feel.
Email your thoughts to Jennifer.Hughes@mass.gov.
Use the subject line: “EEA#16570 WT-11 Transmission Right-of-Way Reliability Project.”
Be sure to insert your name, address, and contact info.
SAMPLE
As a resident and voter in Massachusetts, I implore MEPA to require Eversource to revise their plan, which neglects to minimize harm. Eversource doesn’t acknowledge the irreplaceable value that forests have to people, animals, and the climate, and their plan does not show due care in distinguishing between trees that pose a risk to powerlines and those that do not.
In response to the substantially similar plan that Eversource submitted in 2022, “over 339 comment letters,” as the EEA certificate noted, “expressed concern for endangered species and wildlife habitat, sensitive wetland areas including drinking water supplies and cold water fisheries, and the future use of herbicides on the newly cut areas… [as well as for] protected open spaces.” Eversource's current plan ignores these concerns. It only excepts six acres that they would have clear-cut before, while still proposing to clear-cut 278 acres.
A reasonable Eversource plan would minimize harm with principles such as the following:
● If trees are too far from the wires to pose a risk, don’t cut them.
○ Calculate this rationally, factoring in distance from the nearest wire, height of the nearest wire, and topography. Leave trees taller the further they are from the wire. It’s unacceptable to limit all trees to just 30’ tall when they’re all further than that from the wires, and up to 100’ away from wires that are up to 96’ high.
○ If there are exceptions, where trees that are safe for the wires must nonetheless be cut, specify why. If the reason is access, explain how so, given that the currently-cleared corridor is already far wider than most roads.
● Target trees that pose an emerging risk, rather than all the trees that might conceivably pose a risk over the next 40 years. Plan to manage record-breaking trees individually as needed, rather than assuming that all trees will be record-breakers.
● Favor selective management over clear-cutting. Favor pruning or topping over cutting. If doing so is too costly or impractical project-wide, then implement it in the more sensitive areas of the project, such as riverfront and wetlands areas and state-designated Priority Habitats of rare species.
● If some areas are still to be clear-cut, analyze outage data to establish the point at which further widening doesn’t reduce risk more than it increases drawbacks.
Eversource claims that they need to clear-cut because of industry standards, but they misrepresent those standards. The standards do recommend managing vegetation across their ROWs, but they don’t say to clear-cut. They mandate an annual plan, not a 40-year one. The FERC/NERC report defines a “danger tree” as “any tree that, if it fell, could contact a transmission line.” Eversource is calling every tree a “danger tree,” when only a subset of trees will ever become danger trees, and an even smaller subset is a danger tree now.
As it stands, Eversource’s plan would cause substantial, avoidable harm to the environment, people, and the planet. I ask that you exercise all authority to see that they distinguish between trees that do and do not put the grid at risk, so that they prune, top, or cut the former while preserving the latter.
Sincerely,
Your name, address, phone number, and email address here