January 30, 2008
Sierra Club Raritan Valley Group
822 Vosseller Ave.,
Martinsville, NJ 08836
732 560-0360
Assemblyman Peter Biondi, BPU Commissioners,

The Raritan Valley Sierra Club Group on behalf of many citizens who have contacted us, ask your assistance bringing the NJ Board of Public Utilities rules for vegetation management (NEW JERSEY ADMINISTRATIVE CODE [NJAC] Title 14 - Board of Public Utilities, Chapter 5 - Electrical Service, Subchapter 8/9 - Vegetation management) closer in line with the federal guidelines (Standard FAC-003-1 available from the North American Electric Reliability Corporation [NERC]).

The Federal rules require "vegetation clearance to prevent flashover between vegetation and supply conductors."

The 2006 NJ BPU rules require clear cutting any trees which have the potential to grow over 15 ft. out to the edge of their right-of-way, which in many cases is 75 ft. from the center of the power line. This is a much larger area than they have trimmed in the past and frequently goes into peoples back yards. The current revision to the rules, has left this provision in despite complaints from many citizen and local government groups. The NJ rules not only exceed those of the Department of Energy, but those of most other states.
The NJ requirements have been extended to 69 kV lines which is beyond the federal guidelines.

Trees could be up to 30 ft tall 50 ft from the center of the power line and still be 1 1/2 times the safe distance to avoid flashover according to the federal guidelines.
The two figures attached show the difference in these requirements.

The reason the BPU staff gives for these strict guidelines is that the utilities need room to maneuver large cranes for emergency repairs in the event that a tower falls over because of wind and ice or terrorists (sabotage).

We think this needs to be reconsidered:

1. The towers are over-engineered to withstand the most severe kinds of weather. We could find no record of a tower collapse because of weather. If there was, the towers should be strengthened because a 100 ft. tower would land dangerously close to homes.

2. Saboteurs are not likely to attack near someone's home.

We support the Somerset County Freeholders draft resolution which states:
"Clear cutting can have significant environmental and community character impacts, particularly for established neighborhoods, scenic corridors and high integrity forest subwatersheds, as well effect on the quality of life of neighborhoods and the ecological intergrity of natural systems that are located near the Electric Distribution Companies (EDC) Rights of Way."

In addition it has impaired the property values and quality of life of residents whose properties adjoin these Rights of Way.

Our web site has more information at: https://donsnotes.com/sierraclub/RaritanValley/bpu_veg_mgmt.html


  Don McBride, Sierra Club Raritan Valley Group Executive committee.

Att: Tower Diagram Fed Reg
Tower Diagram NJ BPU Reg