Tuesday, May 25, 2010

LORAX letter of Support for Vegetation Management Notification BIll

Hon. Andrea Stewart-Cousins
805 Legislative Office Bldg.
Albany, NY 12247 May 24, 2010

Dear Senator Stewart-Cousins,

The GEF LORAX Working Group fully supports the goals of Senate Bill S-6825 (Assembly Bill A-10003) and urges that this important piece of protective legislation be released from Committee to allow for a full chamber vote.

The bill’s requirement for a general notification of all potentially affected property owners (private and or municipal) 60 days before the commencement of any vegetation management activity provides a good baseline to ensure timely disclosure.

The bill’s further requirement for a public hearing 30 days prior to any vegetation management program commencement ensures that Con Edison and the other state electric utilities will be more transparent concerning the true scope of planned vegetative management work. Since Con Edison (as well as the other utilities) commonly use sub-contractors to do vegetation management, the legal record / transcript of a public hearing helps to ensure that communities and individual property owners are protected from a utility’s or sub-contractor’s failure to comply with the work order as described.

Critical to the success of any such notification legislation will be the specific regulatory details of the notification process as developed by the Public Service Commission and as applied to each state electric utility, including: notification methodology, notification retry requirements, provision of a full description of intended work, property owner notification sign-off, and scope-of-work / mitigation arbitration for handling disagreements.

The PSC’s directive, PSC 04-E-0822, appears to be a ‘one size fits all’ approach to vegetation management throughout the State, and has not taken into consideration the differences in approach that are needed in the more densely populated suburban areas, as opposed to measures used in rural areas. Public meetings concerning planned vegetation management will give a much needed forum to voice the community’s commitment to the environment and its concerns about the impacts of climate change, habitat destruction and property value loss.

As part of the Greenburgh Environmental Forum (GEF), the LORAX Working Group is committed to educating the public about the complex issues surrounding both transmission line and distribution line vegetation management, as well as finding legislative and procedural solutions to these issues. The LORAX group looks forward to working with you and your staff to ensure that the "Notification Bill" S-6825 is passed quickly in Albany. Please let us know how we can best support your efforts to expedite the changes we urgently need.


Mark Gilliland (Chairperson, LORAX Working Group)
85 Harriman Road
Irvington, NY 10533

Cc: Anne Jaffe-Holmes, LORAX WG

Read the Westchester County BOL's letter of support for the notification bill (pdf).

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