This regulation should be fully rejected due to the lack of complete cost-benefit analysis presented in the proposed regulation change.  In addition no fast tracking of this regulation change should occur due to the incomplete analysis presented.

The proposed change only considers the private (business) benefit of tree removal and pruning in the ROW.  There are significant benefits to the public that are not being taken into consideration and which are greater benefits to the public than benefits to businesses.

A complete cost-benefit analysis should cover both the private (business) benefit and the public cost.  Anything less provides incomplete analysis and should result in rejection of the rule.  Trees provide important public benefit that also reduce the impacts of increased intensity and frequency of precipitation or wind events due to climate change and improved water quality benefits.  These include shade, protection from wind, stormwater absorption and filtration, erosion control, reduced urban heat island effect, absorbing pollutants from the air, noise buffering, slowing down the impacts of heavy precipitation events through their leaves, and wildlife habitat.  

This regulation should be fully rejected due to the lack of complete cost-benefit analysis presented in the proposed regulation change.  In addition no fast tracking of this regulation change should occur due to the incomplete analysis presented.