Sunday, May 29, 2011

Published Order for Case 10-E-0155

Here is the pdf of the Case order released late last week by the PSC.

While the guidelines, commentary and discussion are more detailed that that of the original Press Release, it must be noted that in many areas, these new guidelines fall short of what LORAX had hoped to achieve. The most apparent lack is that of public oversight / review / comments on new TVMPs and related procedures for high density ROWs, etc. Another area of lack relates to detailed environmental, bio-habitat and ecosystem services analysis. It is unclear how enhanced guidelines for ROW management and the now-required mitigation planning can be created without these science-based tools forming a baseline.

Finally, there is an extended discussion about a modified "tiered" vegetation management approach - essentially adopted in the DPS staff commentary on the guideline which states that preferred vegetation should be left in the ROWs, rather than simply undertaking clear cutting. In this discussion by DPS staff, the LORAX provided diagram outlining "tiered management" is dismissed as being too rigid and not reflecting the need for adoption of a variable approach based upon site specific ROW conditions due to tower type, terrain and wire placement. This is unnecessary obfuscation on the part of DPS staff - it as clear from LORAX materials that the diagram was an example of the possibility of using this technique without hazard, not a rigid "one-size-fits-all" mandate on heights and distances. In any case, the final outcome should be better vegetation management decisions based upon actual site conditions. Which is good.

Other good guideline updates include the requirement (of Con Ed and O&R) for proper and clear advanced notification, enhanced training of contractor work crews, as well as the requirement to provide contact information for VM complaints and questions - provided on notifications, on web sites and by in-field contractors when asked.

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