If a town’s Conservation Commission approves of only a very light, environmentally sensitive touch in managing vegetation within the 200’ riverfront or wetland buffer, will you heed their decision?
If you will honor it, but with exceptions, what are those exceptions?
Are your maps’ pink cross-hatched areas of “exempt maintenance” exceptions, or will you heed their decision there, too?
Q: Why does your Alternatives Analysis only compare strawmen, not real, viable alternatives?
Why don’t you analyze selective management? You imply you are doing so by eliminating six acres that you realized posed no risk from your otherwise-284-acre project. But that’s a dodgy spin on the meaning of selective management.
The commonly accepted definition, as explained in the federal standards you cite, is targeting risky vegetation within a cut zone, while retaining vegetation there that’s compatible with grid safety. That definition is also consistent with your own prior version’s map-set legends, which had color-coding (which you’ve since removed) for “Selective tree removal” zones.
In your ROW, don’t you already inspect and manage vegetation that poses a risk to the grid at least annually, as directed by the federal standards you reference? Wouldn’t you continue doing so even if you didn’t clear-cut 278 more acres in this project, and ~2000 more in your next seven years of projects in Western MA? Why isn’t that most basic alternative represented in your analysis?
Why do you include “No Action” instead – an obviously untenable approach that wouldn’t meet federal standards, and that artificially makes your preferred method look better by comparison?
It's understandable that, as you state, “it is often difficult to avoid/protect [trees]... that are interspersed with incompatible” ones, but the inability to preserve every non-target tree doesn’t justify not trying to spare any.
When analyzing the alternative cut zone widths, why do you inflate estimates of danger trees? Your plan calls for clear-cutting all the trees that might, if they broke records, pose a risk to the grid anytime in the next 40 years – plus all the other trees in the same 100’ swaths as those trees.
What if you used plausible predictions? You report that you chose the very tallest conifer and the very tallest deciduous tree surveyed. Despite acknowledging that “only a small number of the thousands of trees [in the LiDAR survey] had existing heights close to these,” you then added eight more feet to those heights to account for how tall trees might get over the next 40 years. You figure on that record-breaking height being every tree’s future height. What if instead, you made a more plausible prediction, with rare trees breaking height records, rare ones never growing at all, and the rest on a bell-curve distribution in between? In that case, how would your figures throughout change?
Why do you propose to cut trees based on how far they might grow in 40 years (if they all broke records)? The NERC standards you provided repeatedly reference an annual vegetation management plan, and never anything like a 40-year one. I can see wanting to reduce your annual expenses, and certainly it’d be nice for many of us to do our jobs once and then not have to do them again for 40 years. But that seems like an exceptionally long work interval, and one that means cutting thousands of trees now when you otherwise could preserve their many benefits for decades.
Is your analysis of alternative cut zone widths based on danger trees, or all trees? The FERC/NERC report you provided defines a danger tree as “any tree that, if it fell, could contact a transmission line.” In Tables 3-2 and 3-3, you report how many “Trees within Striking Distance Remaining” would exist under each alternative scenario. E.g.:
6475 (and 10,021 in 40 years) under the “No Action” alternative.
183 (and 226 in 40 years) under the “100 Feet Modified” alternative. (I.e., you’ll cut 6292).
Is that counting all of the trees in those zones? Or just the danger trees? (I.e., if there’s, say, a 100’ tree, 80’ from the closest wire, and that wire is 70’ up – is that tree included in the 6475? Or excluded, because it wouldn’t be able to reach the wire now?)
If it’s counting all the trees in the 100’ swaths, how many of those are danger trees (calculated more plausibly, as described above), and how many are collateral damage?
Or, if it’s just counting the danger trees in those swaths, what is the total number of trees you’d cut there, including the collateral damage?
How do those proportions change as you get further out from the wires in your cutting swaths?
What is the threshold proportion of danger trees to collateral damage below which you’d continue selective management instead of clear-cutting? There must be some threshold below which selective management is the rational choice, because otherwise, very many trees could be clear-cut even if very few are danger trees.
You decided against cutting beyond 100’ out from the outer wire on each side, even when your ROW is wider. Is that because the proportion of danger trees to trees is too low to merit clear-cutting? What is that threshold? How does it get established?
Is that threshold lower in sensitive areas such as riverfront buffers and Priority Habitats?
Why don’t you appear to calculate the proportion with reasonable granularity? If you did, wouldn’t your map differentiate between areas that do and don’t meet the threshold, with only the former being clear-cut? And with the latter being more predominant the further out from the wires you get?
Why is each alternative only considered on an all-or-nothing basis? Even if it’s not feasible to apply less destructive methods project-wide, why don’t you analyze applying them to one or more tiers of the project’s most sensitive areas (e.g., riverfront and wetland areas, state-designated Priority Habitat for rare species, etc.)?
Why are you proposing to clear-cut trees that won’t ever reach the wires?
If cutting trees is meant to keep them from wires, why would all trees that could get taller than 30’ be cut, when they could be so much taller before they’d be anywhere close to the wires? Why aren’t even the most basic calculations applied to determine the allowable height of a given tree, provided its distance from the nearest wire (up to 100’ away) and the height of the wire at that point (up to 96’ in the air)?
You say that the project “will consist of the removal of tall-growing trees and shrubs, those that have mature heights greater than 30 feet…” How will you preserve the vegetation that’s shorter than, and will stay shorter than, 30’? If you can do that, why not also do it for all vegetation that’s shorter than the safe distance to the wires, calculated as just described?
E.g., Why do you propose to clear-cut the riverfront base of a gorge where the elevation is 360’, and the bases – not the tops – of the towers on each side are at 500’ and 530’? (Consider that the tallest tree in MA is a 163’ white pine, and that other species have lower maximum heights – e.g., the tallest hemlock in MA is 132’, with 60-70’ a more typical maximum.)
Why do you imply that federal industry standards require you to clear-cut? The NERC standard you provided leaves defining a work plan up to the utility, but refers to ANSI Standard A300, Part 7 as a common choice. That standard includes both selective and non-selective management, and says to employ the latter “whenever there is sufficient compatible vegetation actively growing on the right-of-way,” and “[w]here rights-of-way cross surface water resources” to “create a buffer, retaining as much compatible vegetation as possible.” Your proposal implies that you’re proposing to clear-cut because standards require it of you. That seems intentionally misleading. Is there another explanation?
Many of the public comments on your EENF asked how many outages there have been in this project’s footprint. You answer by providing Table 2.1, listing dozens of outages. But:
None of those are on line 354, which makes up 28 of this project’s 29.3 miles.
None of them are on line 1604, which makes up some of the rest.
The remaining line of the project is 312. You list two outages as being on line “312/393.” 393 isn’t in the project footprint, and it's unclear if all of 312 is.
So I’m asking again on behalf of everyone who asked before:
How many outages have there been in this project’s footprint? Have there been any?
If so, how wide was the cleared corridor at that time and place?
How many outages per decade is the proposed plan projected to prevent, as compared to a less destructive management approach? How do you go about determining how many acres of damage are a reasonable tradeoff for a given reduction in risk?
What data have you analyzed correlating outages on transmission lines with corridor widths where and when they occurred? What have you learned from that about the demonstrated benefits of increasing a cleared corridor’s width, and the point at which further widening no longer yields enough benefit (as compared to selective management) to outweigh the drawbacks?
If you haven’t done that analysis, then why would you posit that your current 125-335’’ cleared width isn’t already doing its job?
Per Map 58, you’re proposing to clear-cut the steep slopes from North Valley Rd. right down to the brook, where the rockslide occurred in the 1950s, destroying that portion of North Valley Rd. and causing downstream flooding. You claim that stability “will not be significantly compromised” because you’ll leave roots and use mats and water bars to control the risk of erosion or another rockslide. But roots decay, and mats and bars sound impractical on a vertical rock face. How will destabilization risk be independently assessed, and compensated if it does occur?
Presumably, you’re proposing a 40-year plan, and a non-selective one, because it’s economical. How much money would this plan save Eversource versus continuing annual, selective management, and how much of the savings do you commit to passing along to your customers? What reduction in our bills will the average residential customer see?
What about across all ~20 projects you plan in Western MA in the next seven years?
Trails are missing from some maps where you propose clear-cutting. How can these trails be added so that your planning can account for them?