Several Environmental Committee members have focused enormous energy into providing the County staff with legal rationale that will enable them to control any agreement with PG&E rather than just following what other counties or cities have done. In essence not allowing PG&E to continue removing trees, but to prevent ANY tree removals until each individual tree has been proven to be a safety risk and until PG&E complies with all local, state and federal environmental regulations.

This was accomplished by the incredible in-depth research that Paul Norcutt has done. He looked into Federal, State and local documents relating to pipeline safety, lawsuits, and all sorts of regulations — and found significant legal policies and regulations, along with letters and other information to back up our statements. Way to go, Paul! Kevin Collins has been reading all the transcripts from the lawsuit by the Feds against PG&E for their failure to comply to regulations that let to the San Bruno tragedy, and that has helped too. Chuck Baughman’s visit to the trees with Oak tree expert Al Keuter brought out PG&E’s numerous errors in identifying tree species. Jennifer’s legal expertise enabled us to evaluate the relevance of the documents Paul found, so that solidified effort.

Take Action!

The next step is to add our voices to those who have reached out to Assembly Member Mark Stone and State Senator Bill Monning, asking them to help intervene with the California Public Utilities Commission, to forestall further tree removals.

The following information was presented to the County and will be presented to our State representatives as well…

VALLEY WOMEN’S CLUB’S ENVIRONMENTAL COMMITTEE AND CONCERNED CITIZENS OF SANTA CRUZ COUNTY

IMPORTANT POINTS ABOUT, AND OBJECTIONS TO, THE PG&E “COMMUNITY PIPELINE SAFETY INITIATIVE”

We question the validity of the professed necessity of removing thousands of trees along PG&E’s pressurized natural gas pipelines, and we believe that PG&E, by not following applicable environmental laws has failed to properly assess and address significant potential adverse consequences of the removal of the trees. Nor has it provided any of their research (if any) in this regard for public review. In addition, PG&E’s leak-response processes apparently disregard Federal pipeline safety regulations; if Federal rules are followed, gas is turned off, removing any issue regarding living tree roots limiting access or slowing down the process.

Point #1

The County and State should prevent any tree cutting until and unless PG&E files a complete and transparent plan that is subject to all environmental laws and public input that any other entity performing a mass cutting of trees would be required to provide.

• PG&E representatives stated on May 11, at a meeting of Supervisor John Leopold’s constituents, that private property owners can say “no” to any tree removal; the County also has the right to say “no,” according to Federal Office of Pipeline Safety Regulation, PI-ZZ-049.
• PG&E’s Initiative results in unnecessary felling of a wide variety of trees, including endangered, rare and heritage species such as rare Ponderosa Pines and Shreve Oaks, and century-old Redwoods. PG&E has inaccurately identified many trees, including rare oak tree species on Graham Hill Rd. that should be protected. This is untenable and demonstrates that PG&E’s research and claims are flawed and need oversight and public review.
• Any other entity with such a massive project would be required to abide by all County and State environmental regulations. PG&E has not asserted that this project is “urgent” nor that there is any “clear and present danger” that necessitates immediate tree removal. Therefore, there is no reason that PG&E should be exempt from all applicable County, State and Federal environmental regulations for this project, including at minimum:
  • County General Plan 5.10.10 and 5.10.15 – Designation Scenic Roads (Graham Hill)
  • Sensitive Habitat Protection – 16.32

Point #2

The stated reason that PG&E wants to cut down the trees is to have “rapid access” to the pipeline for “safety reasons,” however they have not substantiated any safety threat from the living trees. Safety is most directly impacted by shut-off valves and “piggable” pipelines.

• At Supervisor McPherson’s public meeting on May 24th, PG&E insisted that safety and access were the reasons for cutting the trees. However, for safety, rapid access to pipelines (digging down to reach them to deal with a leak) is secondary to the necessity of immediately shutting down the pipeline. As stated in 49 CFR 192.615 the essential element of a response, is a shutdown of the pipeline to insure safety of people and property. This is not PG&E’s preferred method, preferring to treat the leak without shutting down the gas. Once shut down, however, the small time savings realized when cutting through dead roots over living roots is irrelevant.
• To the best of our knowledge, in the last 70 years there have been no deaths or injuries related to trees inhibiting access to a pipeline.
• As of December, 2015, PG&E has installed 217 automatic shutoff and remote control valves, within 522 gas transmission pipeline miles, as required by Federal mandate, according to NTSB (letter to PG&E on 12/1/2015). Additionally, Jesus Soto, the Senior VP of Natural Gas Operations for PG&E, stated that PG&E has begun operating leak detection vehicles which are 1000 times more sensitive in detecting leaks than previous methods. Thirdly, at the April 6^th meeting with Supervisor McPherson, PG&E representatives stated that every transmission pipe in the County was hydrotested and is thus “piggable.” (That is they have the ability to be inspected automatically with inspection devices, or “pigs” that travel through the pipes.) These transmission pipes, we are assured by PG&E, have been inspected, and found to be defect free. All these measures both mitigate and eliminate the need for any tree removal and do not support wholesale tree cutting along the pipeline as proposed by PG&E.
• Point #3 Rather than being a liability, trees are integrally related to the safety of the pipeline and the stability of the land. Removal of trees significantly jeopardizes soil stiffness, and soil stability by inducing 1) slope failure, 2) subduction, 3) erosion, and 4) liquefaction. Living trees and their roots support the soil during earthquakes as well. Additionally, there is evidence that having trees present actually adds some protection in the event a gas explosion occurs.
• “Soil stiffness” is required to prevent pipe failure.
• ASME/ANSI B31.4.2012 section 401.2.3.1 requires pipelines to be responsive to the effects of an earthquake. Dead roots will not support pipelines; living roots will.

IN SUMMARY

There is no reason that PG&E should be permitted to continue cutting down trees as a part of this Initiative, until and unless the State and County, and the public, are all provided with specific data as to the threat posed by each specific tree. In the event such proof is provided, then any tree removal must be subject to public input and all applicable laws.