Background and Detail:  Utility Tree Pruning and Removal

Click for News Coverage covering past and current media reports, Prior Petitions and Past Public Meetings, and List of Documents on utility tree pruning and removal, including filings with the Two Storms Panel and PURA by GCNH and New Haven URI, Items 16-20.  See Item 5 for GCNH Testimony and Comments to PURA.   For additional background information, see Previous Updates.  Check Recent Information, Notices and News for current information.  The following was written beginning in late November of 2013, and has not been updated since shortly before the PURA hearings in Docket No. 12-01-10 in March of 2014.  Click PURA Docket No. 12-01-10 and Legislation for more recent information. 

• United Illuminating has adopted a vegetation management plan that potentially removes all street trees under the utility wires in New Haven and all other UI served towns and cities:  Ansonia, Bridgeport, Derby, East Haven, Easton, Fairfield, Hamden, Milford, North Branford, North Haven, Orange, Shelton, Stratford, Trumbull, West Haven and Woodbridge. The plan calls for the removal of all trees and branches within 8 feet on either side of its electric distribution wires from ground to sky (now known as the Utility Protection Zone), excluding ornamentals and other low height trees.  This type of pruning/tree removal is commonly called Enhanced Tree Trimming or ETT.  UI has previously used U or V-shaped directional pruning to run wires through the tree canopy, and reports that it has worked well for average New England weather.  The possible consequences for one New Haven street of this change in pruning and removal practices are illustrated below:    

Edwards Street in the Fall of 2013

Approximation of Edwards Street after removal, but without wires and poles that would remain. Tree on front right would also be removed. Stumps about 3 feet in height could remain, since UI has not committed to stump grinding.

• The UI plan has been approved by the Public Utilities Regulatory Authority (PURA), subject to revision of scheduling priorities.  Pilot projects are scheduled to begin in selected areas of Hamden, Orange, Shelton and Bridgeport in January of 2014.  Tree removal is already occurring in Orange and Shelton. Full distribution line clearance is scheduled to begin throughout the UI served communities in June of 2014. 
• The UI plan does not commit to replace trees that are removed with right tree/right place trees, except perhaps on a case by case basis, nor does it commit to grind the stumps remaining after tree removal. 
• CL&P's System Resiliency Plan was approved by PURA on January 16, 2013.  CL&P has used ETT for many years, but not on all of its distribution lines and, it seems, not as aggressively.  Under this most recent plan, CL&P has expanded the use of ETT, and now refers to use of ETR (Enhanced Tree Removal).  To meet the rigid line clearance standards of ETT--8 feet on either side of the wires from ground to sky--healthy trees have to be removed, either because the whole tree is within the 8 foot area or because so much of a healthy tree would have to be pruned away that it must be removed in order not to create a hazardous tree. 
• Electric utilities (CL&P and UI) must obtain a tree warden permit or a permit from the Department of Transportation (DOT), for state highways, to prune or remove trees in the public right of way, and abutting property owners may object to pruning and removal of non-hazardous trees.  See, summary of law regarding tree warden permits and notice to and right to object by abutting property owners, new requirements for tree warden training, and description of tree warden school and history of tree warden laws in CT.  Section 13a-140 governs DOT permits, requires written notification to the chief elected official if there is a tree greater than 18" in diameter and permits municipalities to enact an ordinance providing for a civil penalty for illegal pruning or removal on a state scenic highway in the municipality.  Whether you are in CL&P or UI territory, if you are concerned, contact your tree warden and other municipal officials, such as the mayor, first selectman, legislative council members, conservation, economic development or historic district commissions.  Be alert to notices from the electric utilities, which are likely to come by regular mail, and file your objection in writing within the time limits. 
• A tree warden's or DOT decision not to issue a permit or to uphold (or reject) a property owner's objection may be appealed to PURA.  In the past, UI and CL&P have worked out agreements with objecting tree wardens, DOT and property owners rather than appealing, but UI's plan indicates that UI will appeal.   Partly to allow for the time required for appeals, the UI tree removal plan is scheduled to complete all removals in two "passes" over an 8 year period.   CL&P has already appealed a tree warden refusal in Essex.
• Although some apparently healthy trees may need to be removed, due to root growing conditions or problems specific to the tree species, wholesale removal of healthy roadside trees imposes significant costs  on communities, their residents and businesses due to the loss of the benefits provided by healthy roadside trees.  These and other benefits were described in the State Vegetation Management Task Force Report, as follows:

            reduced energy costs
            increased property values
            increased business income
            reduced flooding, stormwater runoff 
                and erosion problems   
            improved air quality
            reduction in carbon

improved mental and physical health
noise reduction
safer communities
habitat and food for birds and animals                      protection of street pavement
traffic calming (reduction in traffic speed)

• The costs of losing the benefits of healthy roadside trees outweigh the improvement in power reliability that such cutting in the Utility Protection Zone might produce.  In recognition of these benefits and the importance of street trees to a community's character, the Task Force Report envisioned a long term transition to "right tree/right place" roadside trees, replacing dead and declining large trees with trees that pose no risk at their mature height of growing into or falling on electric utility infrastructure.  It did not call for removal of all healthy roadside trees within the Utility Protection Zone.  It did call for immediate removal of hazardous trees.  ETT removes both hazardous trees and branches and healthy trees and branches.  The data indicating some reduction in outages from ETT does not permit analysis of the extent to which removal of healthy trees within the Utility Protection Zone is important to that reduction.   Although no formal study has been done, observers have reported that from 50 to 70% of outages from storms are caused by trees falling on wires from outside the Utility Protection Zone.  In its Final Decision, Docket 12-06-09, p. 12, PURA estimated, based on consultant reports, that 78% of tree-related power outages during the two 2011 major storms were caused by trees that were outside of the "normal trim zone."  In some towns, 90% of the power outages caused by trees in the two storms were said to come from outside of the "normal trim zone." 
• Documents pertaining to PURA and Utility Tree Pruning and Removal (See Previous Updates and Recent Information, Notices and News for information released in connection with the March 2014 PURA meetings and thereafter.):  Click to read UI's plan, CL&P's plan, as described in testimony, and PURA's approval of the CL&P plan, the Urban Forest Council's response to UI's plan for removal of street trees, the State Vegetation Management Task Force's Exceptions to a PURA Draft Decision on Tree Trimming in Docket No. 12-01-10, and the Task Force Chair's oral argument in support of the Exceptions before PURA on December 20, 2013.  PURA transferred its consideration of utility vegetation management (" tree trimming"), required by Public Act 12-148, to Docket 12-01-10, Tree Trimming, which it had earlier opened on its own motion.   (The transfer is made in Final Decision, Docket 12-06-09, p. 12- 14 [extensive discussion of vegetation management issues highlighted].  See also Department of Energy and Environmental Protection Deputy Commissioner letter filed in Docket No. 12-01-10.  Docket No. 12-01-10 is a separate proceeding from the proceedings in which UI's or CL&P's plans for tree pruning and removal were approved.  See also, the Garden Club of New Haven's testimony in this Tree Trimming docket, July 31, 2013.  March 4, 2014 Comments of the Garden Club of New Haven for March 5 and March 6, 2014 Public Meetings. Comments of the Bureau of Natural Resources, Forestry Division of DEEP to PURA Public Meeting on March 5, 2014.  See Previous Updates and Recent Information, Notices and News for additional, important, information.
• NOTE:  Although existing healthy large trees should be retained, when planting new trees under or near electric wires, plant "right tree/right place" trees!  The Garden Club of New Haven supports undergrounding of distribution wires where feasible as a long term solution, for which planning should begin.  See GCNH and URI letter urging DEEP to plan for maximum undergrounding of utility wires in its Comprehensive Energy Plan, December 13, 2012