URI POSITION ON UNITED ILLUMINATING’S TREE TRIMMING & REMOVAL PLAN The New Haven Urban Resources Initiative (URI) recognizes that uninterrupted electrical distribution is important. However, the organization wishes to emphasize that trees bring many key benefits to our communities and in fact are essential to our quality of life. In addition to their natural beauty, they help to improve air quality and public health, diminish noise pollution, reduce storm water runoff, and lower energy bills through their cooling effect. Therefore, trees should be treated with respect and care. UI's Vegetation Management Plan United Illuminating (UI) has adopted a vegetation management plan that potentially removes all street trees under the utility wires in New Haven and all other 16 UI served towns and cities. 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, excluding trees which reach a low height at maturity such as ornamental trees. The UI plan does not commit to grind the stumps remaining after removal or to replace trees that are removed, except on a case by case basis. In accordance with current law, UI must obtain a permit from the Tree Warden 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. A tree warden's decision not to issue a permit or to uphold (or reject) a property owner's objection may be appealed to Public Utility Regulatory Authority (PURA). The only exception to the permit requirement is that a utility may “prune or remove a tree, as necessary, if any part of a tree is in direct contact with an energized electrical conductor or has visible signs of burning.” Healthy versus Hazardous Urban Resources Initiative supports a balanced approach to securing electric power reliability by removing hazardous trees and branches that pose a clear risk to the electric utility infrastructure. However, URI strongly believes that all healthy trees should be retained. Hazardous trees defined by the UI plan include those that are dead, have extensive decay, or are structurally weak. Since many structurally weak trees are healthy, we believe these trees require careful review by the Tree Warden to determine whether removal is warranted or whether pruning to remove weight loads is necessary to reduce risk to the electric utility infrastructure. Notification and Transparency It is the position of URI that, prior to the removal or pruning of any individual trees, UI should: Comprehensively review all trees, identifying any specific trees that need to be pruned or removed. Provide the fully detailed plan, including number of trees to be pruned or removed and their locations, to the Tree Warden with an ample review period to inspect the trees that have been identified by UI. Give adequate notice to adjacent property owners who might wish to object to proposed removals following the Tree Warden’s inspections. Documentation for Future Analysis of Risk Following the comprehensive plan and review, UI should carefully document all completed work and provide it to the Tree Warden. This information should be made available to the public. This data collection can provide an opportunity prior to and after major storms to determine the extent to which apparently healthy trees cause power outages. Replacement Planting When hazardous trees must be removed, UI should grind or remove the stumps and replace trees with “right tree/right place” trees on a stem-by-stem basis. When healthy trees are removed, UI should grind URI POSITION ON UNITED ILLUMINATING’S TREE TRIMMING & REMOVAL PLAN or remove the stumps and the trees should be replaced on a diameter lost basis. For example, if a healthy 12” diameter tree were to be removed it should be replaced with four 3” inch diameter trees. Replanting locations should be in the near vicinity of the community where the tree was removed, and be approved by the Tree Warden. Wood Debris UI should provide a plan for the disposal of all wood debris to New Haven City Plan, and the plan should be made available to the public. New Haven should not be a repository for wood debris from other towns. Undergrounding of Distribution Wires New Haven Urban Resources Initiative supports undergrounding of distribution wires where feasible as a long-term solution, for which planning should begin.