Limit environmental harm to only the amount necessary to serve the project’s goals:
1. Prefer selective management* to non-selective management.
- Do so more strictly on sensitive lands*
1a. Establish a limit for collateral damage. Only allow non-selective management if an area of trees has above a TBD percent of danger trees*. (NB: it's unclear what a reasonable limit would be, but e.g., an area with 20 trees shouldn't be clear-cut if it only contains 1 danger tree.)
- Require percent of danger trees to be determined granularly, in each small area that might be spared.
- Apply a stricter requirement on sensitive lands.
2. Practice minimal intervention: Don't cut trees if just topping them would work; don't top them if just pruning them would work.
- Do so more strictly on sensitive lands.
3. Require a quantifiable reduction in outage risk to justify a proposed amount of clearing. Corridor-width shouldn't be a profit-driven matter of opinion at this point, when there's plenty of data available on outages.
- Require analysis of the corridor widths where outages have occurred, and whether adequate selective management was practiced.
- Such analysis should answer how wide corridors should be, beyond which point further widening no longer yields enough benefit to outweigh the drawbacks. (NB: It's unclear what amount of risk reduction justifies each acre of clear-cutting, but that's a metric that environmentally-sensitive experts should establish.)
- Require a greater reduction in risk to justify the same amount of clearing on sensitive lands.
4. Require Alternatives Analyses to include legitimate alternatives, not strawmen. The applicant shouldn't choose the alternatives to analyze, because they only include alternatives that justify their preferred method.
- Require alternatives to be considered granularly, not only project-wide. E.g., what may not be economically feasible across an entire project may well be justified on that project's most sensitive lands.
- NB: This idea #4 should be replaced with a broader one, as it's not just the Alternatives Analysis portion of the proposal that is wildly biased: the whole plan and proposal is tailored to the applicant, by the applicant. But Iit's unclear how plans and proposals could be crafted instead.
5. Require cost-savings to be passed along to customers. Prevent profit-driven project designs (such as this one, replacing annual, selective management with a 40-year clear-cut) by requiring ongoing cost reductions that result from such projects to be passed along to customers.
6. Require digestible project descriptions for the public. Eversource has ~20 more projects planned in Western MA over the next 7 years, totaling ~2000 acres. Dense proposals for each are a sure way to exhaust the public, and Eversource would benefit from that fatigue. The summaries they provide in their public outreach are self-serving, communicating what's good about their project. Require proposals to be scrutinized and summarized by environmentally-sensitive, independent experts who provide digestible summaries in time for public comment.
Definitions
Danger trees: Trees that could contact wires if they fell (imminently, not questionably in decades to come).
Selective management: Managing individual danger trees (as opposed to non-selectively clear-cutting zones of trees). (Caution: Eversource spins other practices as "selective"; this is the industry-standard definition.)
Sensitive lands: E.g., Outstanding Water Resources and drinking water supplies, wetlands, and riverfront areas; Core Habitat and Critical Natural Landscape; Article 97 lands, etc.