April 25, 2008

Jeanne M. Fox, President
NJ Board of Public Utilities
2 Gateway Center, 8th Floor
Newark, NJ 07102

Re: Vegetation Management Rules NJAC 14:5-9.6

Dear President Fox,

I submit the attached analysis of the requirements of NJAC 14:5.9-6 for your consideration in your upcoming discussion on that section.

In our state with its rich topographic and geographic diversity, each span of electric transmission line has its own unique ecological and environmental profile and characteristics. The requirements of proper vegetative management demand individual attention to each of these areas, not a clear cutting strategy.

87% of electric outages are caused by trees falling into lines from OUTSIDE the right-of-way. I remind the President and the Board of the FERC's findings that the 2005 Northeast power outage was the result of the EDCs' spectacularly inadequate response to the catastrophic failure of their own equipment to perform as designed and constructed. This, coupled with a complete lack of an adequate back-up plan, resulted in the outage when contact was made by a fallen tree. The EDCs were at fault, it was not the fault of the tree!

Resources being allocated to clear cut right of ways would serve the public much better if it was spent on maintenance, upkeep and upgrading of the EDCs' aging equipment and infrastructure.


David Barnes