Thanks to Rose Wessel (BEAT) and Cathy Kristofferson (PLAN-NE) for putting together this Action Guide. Please submit a comment to MEPA. Everything you need is in the Action Guide below..
Eversource is proposing cutting any and all trees up to 100 ft. from the power lines closest to the edge of the current transmission line corridor, WT-11 Right-of-Way, which runs from the Northfield Substation in Northfield, south through the towns of Erving, Wendell, Montague, Leverett, Shutesbury, Pelham, Belchertown, Amherst and Granby, to the Ludlow Substation in Ludlow. It crosses 2 EJ communities: Wendell and Amherst.
370.6 acres of forested land would be permanently converted to successional scrub-shrub habitat; 10.1 acres of temporary impacts will occur due to the placement of construction mats to support equipment through research areas during tree clearing activities. Approximately 34.3 acres of bordering vegetated wetland and 2 acres of isolated vegetated wetland will be permanently converted from forested to scrub-shrub/emergent community types. The wetland impacts include crossing rivers, streams and certified vernal pools.
If any cutting is allowed, it should be only carefully identified trees that pose a known threat to the transmission lines. Possible threats from damage from trees can also be avoided by raising transmission lines to a higher level. This was done by Eversource just a few years ago in the Hilltowns.
Notices for this project were not widely shared and the deadline for comments was slated to be August 22. We received word from Senator Jo Comerford that there was a meeting with concerned officials & Eversource and that an extension of the deadline is being negotiated. We will report the new deadline above when it’s determined.
Sources to learn more about this project
Meeting recording: https://senatorjocomerford.org/eversource-power-line-project-meeting/
Project information detailed notes: https://docs.google.com/document/d/1kBRHKSUi8x2EgFr8NCNh6ATHGs5gwsh31By7Midg3YI/edit?usp=sharing
Project documents filed: https://drive.google.com/drive/u/2/folders/16HMZ_1HGpUXpTmVrHS03e2Xj-4K6-12j
SHORT TALKING POINTS:
— There doesn’t appear to be a thorough survey done of which trees along the transmission corridor pose a threat to the power lines. Only trees shown to be geometrically positioned in relation to the power lines in a way that they could do damage, or those likely to grow to that height in the next few years, should be removed.
— MEPA should not grant a certificate until this survey of line height and tree species and placement is completed, submitted and reviewed.
— Power lines in danger of damage by trees falling could also be protected by raising them in height (see diagrams below). This method was employed in the last few years along some segments of Eversource’s transmission corridor, including in Wendell*. *From 8/19 meeting, 47:00 min
— We need trees to act as a carbon sink. This is a key part of carbon accounting in state law for reaching net zero emissions by 2050. MEPA should not be approving a broad tree cutting plan.
— This project is illegally segmented. There are identical proposals for other sections of the transmission corridor, each filed under a different docket number and with different MEPA officials. This creates an unrealistically reduced impact assessment. Eversource should be required to file the FULL impacts of all similar proposals combined.
— Alternatives analysis should include other grid reliability measures such as full system grid mapping and installation of distributed electric storage facilities at all feasible sub-stations.
— Outreach to Environmental Justice communities and host communities has been inadequate. The comment period for this preceding should be extended and public information sessions held.
— A full estimate of greenhouse gas emissions including downstream emissions from use of tree materials harvested has not been provided. The certificate should not be granted until this is completed, submitted and reviewed.
CONTACTS FOR SUBMITTING COMMENTS:
Jennifer Hughes – EEA # 16570
Purvi Patel – EEA # 16567 « Berkshire docket (rec’d certificate), Cc’d because of segmentation
100 Cambridge St., Suite 900
Boston, MA 0211
Re: Eversource WT-11 Transmissions Right-of-Way Reliability Project-EEA # 16570
Eversource WT-02 Transmissions Right-of-Way Reliability Project-EEA # 16567
#16567 was identical plan for Berkshire Co., already received certificate
– Secretary of Energy & Environmental Affairs –
Email not known for sure, use Bcc. for Sec. Card
Bcc: email@example.com firstname.lastname@example.org email@example.com
– Mass Attorney General’s office – firstname.lastname@example.org
– Legislators for the impacted towns:
Senator Joanne M. Comerford – Jo.Comerford@masenate.gov
– Your own legislators. Not sure who they are? Check here!
- throughout the state including:
– total number of acres proposed to be cut
– number of acres of rare species habitat to be permanently and temporarily impacted
– number of acres of bordering vegetated wetland to the permanently and temporarily impacted
– total greenhouse gas emissions from the entire operation.
- From 8/19 meeting, 47:00 min.
Question of herbicides vs. cutting was brought up by an abutter. Eversource informed that this project will not involve herbicides. However, they do use herbicides on shoots of incompatible tree species via targeted spraying under their maintenance programs. Those programs are not large enough to trigger MEPA and go through different permitting.
Questions that should be answered to determine if there is any need for these projects.
*A 25 ft raising of power lines from 100 to 125 ft would eliminate the need for removal of any trees, including those of record-holding height over 150 ft.
**download these graphics: 100 ft. line height ; 125 ft. line height
• GREENHOUSE GAS EMISSIONS
Eversource should be required to include emissions from the project across the entire state.
This should include:
– emissions from the equipment to harvest
– emissions from the end use of the wood
– if that end use is being chipped, dried by burning wood, then burned when dried,
ALL the emissions from that should be included
– greenhouse gas emissions from wetland disturbance and conversion
– loss of the carbon sequestration that would have occurred if the trees had continued to grow and sequester carbon both above ground and in the soil.
Certificate for the first segment of this project (EEA #16567) said,
“project-related reduction in future carbon sequestration will be calculated as the difference between the amount of carbon that would have been sequestered in the future by the affected forest had it not been cleared and the amount of carbon that will be sequestered by grass-scrub/shrub habitat that replaces the forest. The DEIR should account for carbon sequestration from any trees that are removed and not replaced/converted to scrub shrub.”
• ENVIRONMENTAL JUSTICE
We do not believe Eversource did adequate Environmental Justice outreach, especially because our organization was not notified of either project. We do expect to receive notice of projects with potential EJ impacts in our region.
If project proponents are unable to do adequate outreach to residents of the affected towns, they should contract, with compensation for staff time and materials, with local organizations who have established relationships with these communities to do door-to-door, social media, email, and/or mail outreach.
• ALTERNATIVES ANALYSIS
Eversource appears to be focused on projects where they will receive a guaranteed rate of return on their work, rather than on projects that will really increase reliability and resilience. There was no real alternatives analysis for this proposal.
The impacts, costs and benefits of these other options should be compared to:
Furthermore, the cost of assessing parts of the grid should not be borne by those wishing to add small amounts of generation or storage to the grid, and the mapping should not be done piecemeal but rather done in a comprehensive fashion to allow the utilities and grid operator to determine where injection of electricity generated by renewables or supplied by storage into the grid would be most beneficial.
MEPA process needs to be more widely engaged and extended.