Trees are the key to climate change mitigation. The proposed amended regulation does not take into consideration the public cost versus  the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the public cost (loss of amenity, stormwater capture, air purification, etc.). So there is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast tracked. 

This fast track amendment is detrimental to all Virginian's healthy air and rivers!

I've been made aware that VDOT is considering changing tree cutting regulations that will allow more extensive cutting of trees and branches near businesses.  I oppose this change.  VDOT needs to protect as many trees and as much vegetation as possible.  Trees have numerous Service benefits like cleaning the air and absorbing storm water and preventing flooding, to name a few.  The public benefits from lush tree lined streets and highways.  VDOT regulations should be in place to protect as much of trees/shrubs and other vegetation as possible.  Better for the waterways and the citizens of Virginia.  

I oppose the proposed amendment because the analysis neglected to acknowledge tree benefits that include lower crime, higher property value and less flooding. The proposed amended regulation does not take into consideration the public cost versus the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the public cost (loss of amenity, stormwater capture, air purification, etc.). So there is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast tracked.

Good evening,

I've been down this road before in the town I grew up in.  My mother, Shade Tree Commissioner (volunteer position) for our town, planted beautiful honey locust trees on our main street.  Prior planning and approval occurred.  Once they were in, a few businesses complained that the trees were 'hiding' their business signs.  They were in foliage for only 6 months a year, if that, and they were not densely vegetated trees to begin with.  Over time, the shade has great improved visiting downtown and actually increased businesses bottom economic line by having more folks visit during the warmer months.  And, of course, the trees grew above and beyond the height of the signs and were able to be wisely pruned.  Please don't allow VDOT to use this sham of a false reason to trim large diameter trees in street ROW's.  Thank you very much for reading and considering my thoughts.

The proposed amended regulation does not take into consideration the public cost versus  the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the public cost (loss of amenity, stormwater capture, air purification, etc.). There is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast tracked.

This proposed regulation amended doesn’t not properly consider the costs to the public interest and welfare versus the private benefit of the pruning and tree removal that this would allow.  The amendment is focused solely on benefits to private businesses, and does not protect the larger public costs (e.g. stormwater capture, air purification, shade, aesthetics, etc.). This proposal is not based on a credible cost-benefit analysis; therefore, this regulation should be fast tracked.

The final sentence in my just submitted comments was intended to read “…therefore, this regulation should NOT be fast tracked.”

This proposed regulation amended doesn’t not properly consider the costs to the public interest and welfare versus the private benefit of the pruning and tree removal that this would allow.  The amendment is focused solely on benefits to private businesses, and does not protect the larger public costs (e.g. stormwater capture, air purification, shade, aesthetics, etc.). This proposal is not based on a credible cost-benefit analysis; therefore, this regulation should NOT be fast tracked.

I ask that the proposed amended regulation NOT be fast tracked as it fails to take into consideration the public cost of such pruning and tree removal. Rather, the terms of the amendment at this time appear to be motivated strictly by purported benefit to private business with NO reference to, nor accounting of, the considerable public costs such as: loss of the amenity; loss of stormwater capture; loss of air purification; loss of natural resource value. In short, a sufficient – much less complete – cost-benefit analysis is not presented in the VDOT proposal and as such there are no grounds for fast-tracking this regulation. Thank you.

Please do not fast track changes to "vegetation control" in VDOT right of ways. "Daylighting" billboards and businesses by removing trees and tree parts for the purpose of benefiting private business ignores the very real and necessary ecological services that those trees are providing, such as shading areas to prevent heat islands, cleaning the air we breath, cleaning the water we drink. It also ignores the social benefits of trees which include increased property value and beauty. This proposed amended regulation should not be fast tracked as it must not ignore the public good these trees are providing. The regulation should explore the cost-benefit of removing the "offending" vegetation.

Furthermore, this proposed amended regulation seeks to treat two things equally that may arguably not be equal. A billboard is the only means of communicating a message to the public (and thus is arguably more important to keep clear), whereas a business can be found online, via Google Maps, recommended from friends, etc. The visibility needs differ in that regard significantly. 

VDOT's paved road infrastructure benefits us all, but we as resident and customers of VDOT must also ask that VDOT respect the natural resources in their right of ways and retain as much of it as possible to preserve their important ecosystem services. To fast track this change and not further explore additional facets of this regulation is a mistake. 

In the "Rationale for Using Fast-Track Rulemaking Process" it is stated,  "The requirement that any vegetation cut be replaced remains in the regulation, which should satisfy those persons concerned with the environmental impacts of cutting vegetation."

This requirement does NOT satisfy me.  It is not that simple, and there is so much more to consider.

I am a citizen and business owner who is concerned with the environmental impacts of cutting trees and vegetation.  Trees and vegetation help protect against erosion and flooding of roads and properties--that includes business properties. Therefore removing trees and vegetation can have costly consequences.

Trees and vegetation also provide oxygen and reduce air pollution, capture polluted stormwater and contribute to our individual and community health. Therefore, more thought and study-to include a complete cost-benefit analysis- needs to be done. A hastily fast-tracked set of guidelines is not in the public's best interest--and that includes businesses.  

The proposed amended regulation does not take into consideration the public cost versus  the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the public cost (loss of amenity, stormwater capture, air purification, etc.). So there is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast tracked.

In consideration of the costs of this regulation, the costs to the public were not fully explored. Trees provide so much in the way of air purification, shade, storm water mitigation, and these costs were not fully considered to advance the regulation, only the advantages for businesses. For this reason, I do not think that the rationale is fully developed and this regulation is not of a nature to be fast tracked.

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.

The proposed amended regulation does not take into consideration the public cost versus  the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the public cost (loss of amenity, stormwater capture, air purification, etc.). So there is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast tracked.

Particularly in our urban areas, we have a persistent issue with the loss of trees to development and other practices.  Your supposition that this proposal to increase tree removal has no disadvantage to the public or the Commonweath is blatantly false.  Trees provided a vast number of benefits including stormwater management, wildlife habitat, cooling, noise attenuation, beauty, and much more.   Trees absorb CO2 and provide air filtration.  We need to teach the ethic that trees are important and vital to the community and not something to cut down whenever it is a minor nuisance.  

Here in Chesapeake, the Friends of Indian River have been working with partners to increase the tree canopy in the South Hampton Roads cities, including the planting of trees along our roadways.  We have spent considerable time and effort on these projects including using funding from the DOF's Virginia Trees for Clean Water Grant.  This proposal directly negates these efforts by likely resulting in the cutting down of many more trees than we could ever plant. 

Stop and rescind this proposal.

Thank you,

Rogard Ross, President, Friends of Indian River

This fast tracked regulation will lead to increased tree clearing at a time when the Commonwealth is already struggling with decreasing tree canopy. This proposed regulation deserves a full review before being adopted.

This proposal should not be fast-tracked. It only takes into account the private benefit of pruning and tree removal. It does not address the costs to the public. Trees provide tremendous benefits, such as air purification and cooling, carbon sequestration, stormwater catching, and aesthetic benefits. The  potential loss of these benefits must be considered.

I am writing to oppose the use of Fast Track process for adopting the proposed regulation. If adopted, the regulation will have significant impacts to the environment that have not been analyzed by the Agency. A regulation with significant impacts must be subject to a cost-benefit analysis and proper public review and comment. Removal of vegetation impacts Virginia’s natural resources held in public trust - trees provide storm water management benefits, flood control, water quality protection and air quality benefits. Please reconsider the fast track adoption of this regulation so that it may go through an appropriate review process.

Please do not "fast track" the option to cut larger trees in front of businesses. Shade is more important than ever in urban settings to reduce the heat island effect from asphalt and concrete. As the climate gets hotter, large trees are one of the best defenses against climate change because they sequester more carbon dioxide and also absorb more rain to lessen stormwater impacts.

They also add to the beauty of cities and make businesses more attractive, not less attractive. I have never heard of a street tree reducing business and can't imagine this is a real problem, but destroying trees is a real problem.

Thank you for reconsidering!

This amendment is only taking into consideration the assumed benefit to private business and ease of trimming for VDOT.It does not consider the public cost of tree removal. Larger trees are beneficial for stormwater capture, air purification and lowering temperatures-which also are benefits for private businesses. I do not believer this regulation should be fast tracked.

There is growing understanding that a natural bulwark against climate change is mature trees.  Please do not make it easier for actors like VDOT to put at risk a key ally in reducing impacts of severe weather! Trees provide enormous public benefits--reducing flooding, improving air quality, enhancing public health, and reducing energy use, to name a few. Any regulation that impacts healthy trees requires in-depth cost-benefit analysis; please ensure that analysis is done. Until then, these regs should not be fast-tracked. Thank you for taking into consideration the ecosystem benefits of trees and all they do for residents.

First, please stop the Fast-track request for amending the regulation on vegetation control in VDOT right of ways. This entire regulation needs a new look at both aspects it regulates that are  completely different: business frontage and street tree rights of way, and the viewshed from highway rights of ways to billboards. This needs a complete airing to focus on what we now know about the climate impacts of forest loss (loss of carbon sequestration, increasing stormwater runoff), the environmental impacts of declining canopy (increased air pollution, dirtier water, less vibrant ecosystems, and declining natural beauty which invites businesses to thrive in Virginia), as well as a cost-benefit analysis--there is a great deal of new data about the positive economic impacts of trees and shade on businesses, including improved sales, lower energy costs, less crime and rising property values. 

Secondly, please look at this regulation again. There is much to learn about tree removal that impacts ALL Virginia citizens, not just the hard working VDOT workers who now are still required to carefully measure what they seek to remove under this regulation. 

The proposed amended regulation does not take into consideration the public cost versus the private benefit of this type of pruning and tree removal. The amendment only benefits private businesses and does not take into consideration the public impact (loss of amenity, stormwater capture, air purification, shade which will lower temperatures in the immediate area). There is not a complete cost-benefit analysis presented in the proposal and this regulation should not be fast tracked.

Please take this significant change off the fast track.  The proposed amendment doesn't include public cost of pruning & tree removal.  A true cost-benefit analysis takes into account not just the benefit to the private business, but also the cost to the public (loss of tree shade, greenspace, water runoff capture, air filtration, & having a nice place to live/work).   This proposal needs further review to ensure ALL costs are included in the cost-benefit analysis.

Thank you.

I respond on behalf of Audubon Society of Northern Virginia (>5,000 members).  The proposal does not take into consideration the public cost versus the private benefit of such tree pruning and tree removal. The public cost is loss of trees, which includes loss of storm water capture, air purification, mitigation of the heat island effect, and support of local wildlife.  The amendment is framed ONLY in terms of the benefit to private business. Accordingly, we oppose fast-tracking this proposal.

Connie Ericson, Secretary and Advocacy Chair

Cutting of large limbs to "daylight" businesses will damage large trees and not help businesses. Large trees are an amenity and are attractive around buildings and attract people's attention to a building. Damaging a large tree with aggressive cutting of large limbs will not only hurt the tree, it will also make the area around the damaged tree ugly. VDOT is not know for it's ability to manage trees well. Do not let this agency do this.

I do not believe that this regulation should be fast tracked because the benefits of leaving the tree vegetation outweighs the small benefit to only businesses.    Trees purify our air and absorb carbon, which benefits all especially Mother Earth.

The proposed amended regulation does not take into consideration the public cost versus  the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the public cost (loss of amenity, stormwater capture, air purification, etc.). So there is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast tracked. 

This fast track authority should absolutely not be approved. This proposal only considers the supposed benefit to the private business, but fails to appreciate the environmental and social benefits of trees to the public. Mature trees provide critical ecosystem services and social benefits that are not easily replicated. VDOT should focus on ways to keep more trees, not eliminate more trees.

The issue at hand wrongly implies that "there is no disadvantage to the Commonwealth". The impact of climate change is not a theoretical danger looming in the future, climate change is impacting Virginia here and now. Trees are able to slow and absorb water during rainfall events, which we have seen increase in frequency and intensity in recent years. Trees along highways and roads play a critical role in absorbing stormwater and polluted runoff flowing from the large swaths of impervious surface that create our highways. Additionally, the trees are able to absorb air pollution created by car exhaust and many studies have proven that mature trees are capable of absorbing and storing more carbon than newly planted, young trees. The benefits of trees to the health, safety, and wellbeing of Virginians far outweighs expanded ability to cut trees from an area simply to improve the sightline to a business. There are, in fact, studies that even support a greater presence of trees near shopping centers increases spending. I urge you to reconsider this proposal.

It has come to my attention that VDOT is attempting to fast track regulations allowing the cutting of larger trees and limbs in its right of way to daylight businesses.

This needs to be stopped as the proposed amended regulations does not take into consideration the public cost versus the private benefit of such pruning and removal. This regulation only looks at the private businesses and does not speak to the public cost such as storm water removal capabilities and air purification as well as other benefits provided by vegetation.

So without a complete cost benefit analysis, that currently does not exist, this regulation should not be fast tracked.

Steve Spence

The VDOT regulation should not be fast-tracked. We need county-wide prioritization and agreement on planning and preserving tree cover, not piecemeal rules for each utility or business. Deforming and/or removing a large percentage of the branches, no matter what the diameter is an issue. This simplistic rule of trunk or branch diameter cutting does not consider the intent of our green spaces or the long term health of the tree.

This past year we had a terrible event when a different utility (Dominion/Asplundh) removed half of the branches that provided foliage of one of our zoning required mature buffer trees. The workers would not stop cutting even with us screaming at them to stop. I have requested but been unable to access the parameters of the contract between the utility and the subcontractors. Workers should not be permitted to remove double the amount of foliage that is recommended as the maximum for any single year, no matter what diameters the branches are. Hopefully our tree will live following this overzealous pruning. The Sweetgum is a vital part of absorbing water following rains and thereby preventing flooding of our parking area. As a business, we at Frog Pond Early Learning Center are opposed to fast tracking regulations for the purpose of increasing the size of tree trunks or limbs that yet another utility can remove without the planning input of citizens. Contract parameters for pruning in public ROW should be transparent and follow guidelines set by each jurisdiction.

This rule only seems to benefit the private business and doesn’t take into account the public good for both Tree growth, water absorption, shade coverage, air purification, etc. 

this rule should be re-written in a more thoughtful way.

The proposed amended regulation does not take into consideration the public cost versus the private benefit of such pruning and tree removal. The amendment is only framed in terms of the benefit to the private business and does not speak to the environmental and social benefits trees provide to the public, including stormwater capture, air purification, and health benefits. These services cannot be easily replicated. There is not a complete cost-benefit analysis presented in the proposal and I don’t believe this regulation should be fast-tracked.