Saturday, November 5, 2011

PEPCO 3rd quarter meeting MAPP update

This from Joseph Rigby:

The status of the Mid-Atlantic Power Pathway, or MAPP project, can be seen on Slide 12. As we have previously reported, PJM provided us notice in August, on August 18, that the scheduled in-service date for the MAPP project has been delayed from 2015 to the 2019 to 2021 timeframe. This delay takes into account changes in demand response, generation retirements and additions, as well as a revised load forecast for the PJM region that is lower than forecast used in previous PJM studies. The exact revised in-service date will be evaluated as part of PJM's 2012 Regional Transmission Expansion Plan review process. Given the delay in the end service date, we have suspended most permitting, engineering and environmental studies. However, with PJM support, we plan to complete right-of-way and land acquisition in Dorchester County and some permitting and environmental activities at an estimated cost of approximately $5 million in each of 2011 and 2012.

Tuesday, April 12, 2011

Pepco Update...Some delays

This from the office of Bob Jubic, project manager:

We want to take this opportunity to brief you on the status of the Mid-Atlantic Power Pathway (MAPP), a proposed, high-voltage transmission line in the Mid-Atlantic region that is expected to improve electric service reliability.

PJM Interconnection, the operator of the Mid-Atlantic power grid, continues to evaluate electric load forecast data in relation to the projected in-service timeline for MAPP.  An analysis of the aforementioned data is now expected to be completed in August of this year.

MAPP's targeted in-service date remains June 1, 2015.  Even if the in-service date is extended past 2015, there is a need for Pepco and Delmarva Power to continue with the regulatory and permitting processes since such proceedings typically require more than a year to complete.  For example, it can often take up to 18 months or more to acquire environmental permits.  Construction cannot begin until all required permits and authorizations have been obtained.

In addition, the project construction materials, such as the underwater cable, require up to two to three years to manufacture.  That means Pepco and Delmarva Power must reserve manufacturing space well in advance of when the material is actually needed.

Pepco and Delmarva Power continue to believe that MAPP represents the most viable option for addressing future energy needs in Central and Southern Maryland and on the Delmarva Peninsula.  We will continue to provide you with regular project updates.  Meanwhile, if you want more information on MAPP, log onto www.powerpathway.com, call 1-888-641-MAPP begin_of_the_skype_highlighting              1-888-641-MAPP      end_of_the_skype_highlighting, or stop by the MAPP office at 828 Airpax Road, Cambridge, Md., on Mondays from 9 a.m. to 3 p.m., or Wednesdays or Fridays from 9 a.m. to 1 p.m.  Evening appointments are available upon request by calling 410-221-6207 begin_of_the_skype_highlighting              410-221-6207      end_of_the_skype_highlighting.

Friday, April 8, 2011

Maryland Department of Natural Resources Weighs In

 MD DNR questions route  and notes potential  damage from the MAPP power lines and converter station slated for Parkers Creek watershed in Calvert county.


. April 4, 2011
Mr. Doug Boren Loan Programs Office (LP-10)
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
via e-mail
MAPP-EIS@hq.doe.gov
Reference: DOE/EIS-0465
Dear Mr. Boren:
The Maryland Department of Natural Resources (DNR) Power Plant Research Program (PPRP) has reviewed the Notice of Intent to Prepare an Environmental Impact Statement for a Proposed Federal Loan Guarantee To Support Construction of Phase II of the Mid-Atlantic Power Pathway Transmission Line Project, in Maryland and Delaware (Federal Register, Vol. 76, No. 43, p. 12088, March 4, 2011). PPRP appreciates the opportunity to provide comment on the Department of Energy (DOE) scoping of the EIS for the evaluation of potential environmental impacts of the Mid-Atlantic Power Pathway (MAPP) project. In response to the Notice of Intent, I would like to first describe the review process that is used in Maryland for evaluating such projects, and then from this perspective offer specific comments about the issues raised by the MAPP project and the desired scope of DOE's environmental review.
Maryland's Transmission Line Review Process - As you may be aware, Maryland’s process for evaluating transmission line licensing projects falls under the following:
• Power Plant Siting Act of 1971,
• Chapter 31 of the Laws of Maryland of 1971, as codified in Sections 3-301 through 3-306 of the Natural Resources Article,
• Sections 2-207 and 2-208 of the Public Utility Company Article of the Annotated Code of Maryland, and
• Maryland's Environmental Policy Act, Chapter 702 of the Laws of 1973, as codified in Section 1-303 of the Natural Resources Article.
Tawes State Office Building – 580 Taylor Avenue – Annapolis, Maryland 21401
410-260-8DNR or toll free in Maryland 877-620-8DNR – www.dnr.maryland.gov – TTY Users Call via the
Maryland Relay
Under these Acts, the Public Service Commission (PSC) is required to consider a broad range of impacts including socioeconomic, environmental, health, safety and system reliability of any proposed new or modified overhead electric transmission line in excess of 69,000 volts as part of the application review and approval process. In accordance with the Natural Resource Article §3-306 of the Annotated Code, the Maryland Department of Natural Resources (DNR) Power Plant Research Program (PPRP) performs an integral role in the evaluation process and is responsible for coordinating the review of projects requiring a Certificate of Public Convenience and Necessity (CPCN) with other units within DNR, as well as with the Departments of the Environment, Agriculture, Transportation, Business and Economic Development, and Planning (including the Maryland Historic Trust), the Maryland Energy Administration, and other units as appropriate. The purpose of coordinating the review of the proposed project is to assure review by those agencies with regulatory responsibility for managing Maryland's natural, socioeconomic, and cultural resources, and that their comments and insights are incorporated into any licensing or permit conditions. Additionally, evaluating the electrical system need for a transmission project is also integral to the evaluation process. As such, the electrical need and reliability of the transmission project are considered to ensure that the project provides improved electrical service for Maryland and the Mid-Atlantic region.
This coordinated review process culminates in a comprehensive set of proposed licensing conditions and recommendations from the State’s reviewing agencies that insure the proposed project meets all State and federal statutory and regulatory requirements. Although the Environmental Review Statement which DOE will prepare will likely address many of the same issues which will be addressed in the PSC review process, the DOE review will in no way supplant the PSC’s review process. On the contrary, DOE is welcome to utilize the findings of the State review process. The recommended licensing conditions are supported by the preparation of an independent Environmental Review Document (ERD) that details the State’s evaluation of the potential impacts of the project. The process is intended to facilitate the provision of adequate electric power on reasonable schedules at reasonable costs with the least possible depreciation in the quality of the State’s environment.
PPRP has begun preparing an ERD for the Maryland portion of the proposed MAPP transmission line. While this document is not yet complete, PPRP's ongoing review indicates that a number of significant environmental issues merit thorough evaluation – beyond and independent of the material provided by the Applicants - to determine the potential impact of the proposed project. Based on our review to date, I offer below a number of comments intended to address your request to provide input for the EIS scope. Where appropriate, comments have been organized under the topic areas listed in the Notice of Intent.
Project Need and Alternatives – The evaluation of need for a transmission project falls within the responsibility of the state public service commissions and environmental agencies; however, we support the intent of the DOE to consider the No Action Alternative (i.e., the “no loan” alternative) as stated in the Notice of Intent and required under 40 CFR 1502.14(d). Under this alternative DOE may properly evaluate the effects on the regional transmission system of a "no project" or "no build" scenario. We recommend that DOE also consider in the EIS at least two alternatives that meet the objectives stated by the PJM Transmission Expansion Advisory Committee (TEAC) by reinforcing existing transmission routes or building new transmission routes that do not cross Chesapeake Bay.
Additional Alternatives - PPRP supports the intent of DOE, as stated in the Notice of Intent, to "analyze alternatives to portions of the project, such as alternative routes and river crossings, which could lessen or avoid impacts to affected resources". In addition to route alternatives which would avoid crossing of the Chesapeake Bay, we recommend that the EIS consider route alternatives that would avoid the major environmental impacts of the Applicants' proposed route, including the removal or conversion of forested wetlands and the removal or conversion of forested areas in sensitive watersheds or habitats. Specifically, at least one alternative route that avoids the oyster fisheries of the Choptank River should be considered in the EIS. In addition, at least two alternatives to the portion of the route between the Choptank River and the Gateway converter should be included, one that is further south and takes advantage of the Route 50 corridor, and one that proceeds north and east to the existing 230-kV Steele-Vienna right-of-way (ROW), and then utilizes this corridor to get to the vicinity of Vienna. In the segment between Chalk Point and the Western Shore, at least two alternate placements of the Chestnut substation/converter station should be evaluated, including one in which the DC conversion occurs at or near the existing Chalk Point substation. PPRP stands ready to help DOE develop the details of these suggested alternatives at the appropriate time in the EIS process.
Innovative Technology - The MAPP project will use 640-kV (± 320-kV) voltage source converter (VSC) high voltage direct current (HVDC) cable technology with a proposed underground and submarine cable type consisting of solid dielectric cross-linked polyethylene (XLPE) in lieu of mass-impregnated or oil filled cables. While this cable technology is purported to be currently available, having already been installed and put into service, DOE should be aware that such installations are not operating at voltages as high as ± 320-kV. Several planned projects that will use similar technology will not be in-service until 2013 or later. PPRP is not opposed to using new, innovative technology if determined to be feasible; however, it is not clear that the feasibility of this high a voltage technology has been sufficiently demonstrated or in fact even available. Additionally, there is concern that the Chesapeake Bay could suffer irreparable damage as a result of installation, operation and maintenance of such an untested technology. Specific impacts, as described in the following sections, should be evaluated in the EIS.
Greenhouse Gas Emissions and Climate Change - The project clears or converts large areas of forests and wetlands, which will reduce Maryland's carbon sequestration capacity and result in the emission of considerable amounts of greenhouse gases. The EIS should evaluate the following:
- carbon emissions caused by removal or conversion of forests, forested wetlands, and wetlands, and by the disturbance and drying of their soils initiated by construction of the proposed right of way.
- immediate and continuing future methane emissions caused by conversion, disturbance, or hydrological changes to wetlands areas by construction of the proposed right of way.
- annual loss of carbon sequestration services caused by the removal or conversion of forests and wetlands, and total losses expected over the lifetime of the transmission project.
- effects of potential submergence of upland or wetland portions of the proposed right of way due to climate-caused sea-level rise.
Energy Use and Production – In operation, the AC/DC converter stations will produce a great amount of waste heat (in the range of 20 to 50 MW) that will be released to the environment via a cooling system. The converter stations are located in rural areas where this heat release will create a micro-climatological "heat island" effect centered on the converter stations. The impact of this continuing and long-term atmospheric disturbance on local weather patterns (such as precipitation zones and amounts or deposition of particulates) and the resulting environmental changes to nearby agricultural, residential, or natural areas should be assessed.
Water Resources, Including Ground Water and Surface Water – A number of the watersheds affected by the proposed transmission line ROW either have water quality problems or have unusually good water quality. The EIS should assess the effects on water quality, on a watershed basis, from the cleared area of the ROW and substations, the numerous stream crossings, and the increased impervious surface area to be created at substations and converter stations. Particular attention should be directed to the Patuxent River Watershed, the Parker Creek Watershed, the Choptank watershed, the Chicawicomico Watershed, and the Nanticoke Watershed.
Note that the Patuxent River is a Maryland Scenic River and that, in addition to any other regulations, water quality is protected by Maryland's Scenic and Wild Rivers Act. The State's policy is contained in Section 8-401 of the Scenic & Wild Rivers Act, as follows: "The policy of the State is to preserve and protect the natural values of these rivers, enhance their water quality, and fulfill vital conservation purposes by the wise use of resources within their surrounding environment." Construction of the modified Pepco ROW across the Patuxent River and through the Patuxent River Watershed areas in Calvert County may have deleterious effects on the Patuxent River, its tributaries, and its watershed ("surrounding environment") that fall under these protections.
Wetlands and Floodplains - Significant portions of the MAPP project in Maryland are located in freshwater wetlands, estuarine wetlands, forested wetlands, or floodplains. The EIS should carefully evaluate whether impacts on these resources, which are discouraged under Maryland and Federal laws and regulations, can be avoided, and if they cannot be avoided whether the Applicant proposes sufficient and achievable mitigation, both in amount and in function. Specifically, the EIS should consider:
- effects on wetlands and 100-year floodplain areas of the Patuxent River, Choptank River, Chicawicomico River, and the Nanticoke River. Particular attention should be given to evaluating whether effects on the Wetland of Special State Concern associated with the Chicawicomico River north of Route 50 are necessary or justified.
- effects on the Chesapeake Bay Critical Area, including the bottom areas of the Bay and its tributaries to the head of tide, the landward buffer areas around the Bay, and all tidal wetlands associated with the Bay or its tributaries, and evaluate whether those effects are detrimental to the resources in the Critical Area or consistent with Maryland and Federal goals for preserving and enhancing those resources.
Ecological Resources, including T&E species and Species of Special Concern - PPRP and the Maryland Wildlife and Heritage and Fisheries Services have identified many ecological resources and a number of sensitive species habitat areas that will be crossed by or affected by the Project. A set of concerns suitable for EIS scope development is listed below, but other concerns may be identified and added as our review continues. At a minimum, the EIS should consider:
Wildlife and Heritage
- the magnitude of the effects on forests, Maryland's Green Infrastructure, and wetlands.
- the sufficiency of mitigation plans for forests and wetlands, including replacing in kind and function the removed habitat.
- the species and Ecologically Significant Areas identified by DNR's Wildlife and Heritage Service, including those in the Stump Gut Complex site located roughly north of US Route 50 and east of the Nanticoke River; the Stump Point Marshes site located north of the confluence of Chicone Creek with the Nanticoke River; the Chicone Creek Natural Heritage Area ; the Maiden Branch Road Pond site; the Ocean Gateway Ponds site located approximately one mile west of the US Route 50/Route 731 split; the Big Millpond site located adjacent to US Route 50 on its north side; Mockingbird Creek; Riverton Road Powerlines and Riverton Road Ponds; the headwaters of Middleton Branch; the Parker’s Creek stream system; and the West Governor Run watershed.
- species of special concern, including the Delmarva fox squirrel; waterfowl in known historical Waterfowl Concentration and Staging Areas; colonial waterbirds; and Forest Interior Dwelling (FID) birds.
Fisheries
- the disruption to benthic habitat and species that depend upon it for food, spawning locations, or juvenile development - including oysters, blue crabs, resident and migratory fish, overwintering sea ducks, and other sensitive species - from multiple sediment disturbances during preconstruction, construction, and long-term maintenance activities.
- potential effects of thermal modification (including heat content build up over time) of a strip of bottom habitat across the Bay to species that are associated with or depend upon that habitat, including commercial and recreational fisheries in the Choptank River and Bay.
- effects on Submerged Aquatic Vegetation, which provide important spawning and nursery for fish and shellfish in the Bay.
- the size and potential effects of any electromagnetic fields produced by the operation of the submarine cables on the behavior of sensitive fish such as eels, rays, and sharks as well as migratory blue crabs or other benthic organisms that could be similarly affected.
Cultural resources - Approximately 14 miles of the MAPP project would be a new ROW between the Choptank River and the Gateway Converter Station in Wicomico County. In addition, there will be significant ground disturbance associated with excavation and grading for the Chalk Point Substation, Chestnut Converter, Western Shore Landing and Gateway Converter, all of which must be evaluated for archeological resources. Construction of the submarine cable portion of MAPP has the potential to adversely affect submerged archeological resources. Section 106 of the National Historic Preservation Act and Article 83B Section 5-617 and 5-618 of the Maryland Code require responsible governmental agencies to examine the impact of their undertakings on significant cultural resources and to take steps to avoid, reduce or mitigate any adverse effects.
Land Use and Vegetation Management - The EIS should examine whether the proposed ROW, and the NERC-required vegetation management plans, are consistent with County Master Plans, Watershed Restoration Action Strategies, and other local, state, and Federal land-use planning documents.
PPRP believes that a specialized vegetation management plan that can be applied to maintain appropriate woody and associated habitat in riparian zones, woody wetlands, Green Infrastructure areas, and other ecologically sensitive areas within the terrestrial portions of the MAPP ROW will be needed.
Coastal zone management - The Chesapeake Bay is a unique estuary, vital to both the environment and the economy of the State of Maryland. Management of the Bay is shared among a number of agencies of the states that surround it and partner agencies in the Federal government. Central to protecting the Bay and restoring it from its current degraded state is minimizing development in the "Critical Area", defined generally to be the waters of and land beneath the Bay and its tributaries to the head of tide, tidal wetlands, and lands within 1000 feet of the shore, head of tide, or tidal wetland boundary. The EIS should carefully evaluate the MAPP submarine cable crossing of the Bay, with particular attention to the reasoning and purpose behind Maryland's Critical Area Commission regulations (COMAR 27.02.05.03B(d)) that state "Certain new development, or redevelopment activities or facilities, because of their intrinsic nature, or because of their potential for adversely affecting fish, plant, and wildlife habitat or water quality, may not be located on State-owned lands within the Critical Area except in areas of intense development and only after the activity or facility has demonstrated to all appropriate State permitting agencies and the Commission that there will be a net improvement in water quality in the adjacent body of water. These activities include the following:…. (ii) Transportation facilities and utility transmission facilities…"
Visual resources and aesthetics – New overhead structures between Chalk Point and the Delaware state line would range in height from 85 to 195 feet. Four new structures approximately 165 feet high would be constructed in the Patuxent River, parallel to existing lattice structures. The Patuxent River is a Maryland Scenic River. Each unit of State and local government, in recognizing the intent of the Scenic and Wild Rivers Act, is required to take whatever action is necessary to protect and enhance the qualities of a designated river. In Dorchester County, an unknown number of structures would occupy a new ROW on land that is currently forested or in agriculture. Some of the tallest structures in the new overhead segment would span the Nanticoke River. The Nanticoke is the most biologically diverse watershed on
the Delmarva Peninsula. It is free of dams, supports excellent fisheries and has a rich history, evidenced by a number of nearby properties on the National Register of Historic Places.
The project would include two converter stations co-located in Calvert County and one in Wicomico County. Each converter station would have a footprint of approximately 1000 feet x 800 feet and would be 60 to 70 feet high. The Applicants propose to build converter stations in Calvert County adjacent to MD Route 2/4, the only north-south route through the county.
DOE should be aware that the cultural landscape of Southern Maryland is identified by the many federal, State, and local programs that promote it. In conjunction with this, heritage tourism has become a significant economic engine for the region. A potential adverse effect on the cultural landscape therefore has both cultural and economic dimensions. The Southern Maryland Heritage Area Tourism Management Plan is a major blueprint for highlighting the region’s cultural heritage. The Certified Heritage Area (CHA) comprises eleven distinct clusters in Charles, St. Mary’s, and Calvert Counties that are connected by corridors comprising scenic byways, trials and waterways. MD Route 2/4 is part of the Star-Spangled Banner State Scenic Byway in Calvert County and a designated CHA corridor. In Dorchester County, the project would construct an overhead high-voltage transmission line within new ROW through the Heart of the Chesapeake CHA which could potentially affect two State Scenic Byways. The Financial Institutions Article Title 13 Subtitle 11 (§ 13-1112(b)) of Maryland requires units of State government that conduct or support activities affecting a certified heritage area, when conducting a review of activities under §§ 5A-325 and 5A-326 of the State Finance and Procurement Article, assure that the activities will not have an adverse effect on the historic and cultural resources of the certified heritage area, unless there is no prudent and feasible alternative.
The EIS must also consider the many federal programs that overlay the project area. These include the Captain John Smith National Historic Water Trail and Star-Spangled Banner National Historic Trail in Calvert County and the proposed Harriet Tubman Underground Railroad National Historical Park in Dorchester County. Note that the National Park Service (NPS) assessed the potential impact of the Applicant’s previous proposal to rebuild a transmission line between Chalk Point and Calvert Cliffs and concluded that the project did not have the potential to adversely affect cultural resources that could be significant to the visitor experience and understanding of either National Historic Trail. However, the NPS did express concern about the cumulative impacts of this and other transmission projects in Southern Maryland. That the scope of the MAPP project has changed so significantly suggests that consultations with the NPS must be undertaken at the outset of DOE’s environmental review.
Transportation and Traffic – In consultation with the Corps of Engineers, DOE should assess potential impacts from construction of the transmission line to commercial and recreational navigation in the Patuxent, Choptank and Nanticoke rivers.
Noise and vibration – DOE should assess the potential impacts of construction noise to fish, shellfish, benthos and RTE species including, seaturtles, and sturgeon, especially if construction will occur during spawning season for aquatic species of the Chesapeake Bay and the Choptank River.
Hazardous materials and solid waste management - The Chesapeake Bay has been a major ship transportation route since European settlement, has served as the final resting place for material eroded or washed from urban areas and agricultural operations, and has a nuclear power plant on its shores and several more located on the Susquehanna River, a major tributary. Toxic materials from any or all of these sources may have found their way into the sediments of the Bay. The EIS should consider the potential for release of contaminants from sediments dispersed into the water column during preconstruction, construction and maintenance activities associated with the submarine cable portion of MAPP.
Human health and safety - Nutrients may be released from sediments dispersed into the water column during construction of the MAPP submarine cable, and long term operation of the cable may release heat that will have local affects on water temperature. The EIS should consider the potential for stimulating harmful algal blooms (HABs), which have been a recurrent problem in many parts of Chesapeake Bay, including the Choptank River, through increased nutrient loads and water temperature.
An additional potential issue is long-term or seasonal heating of sediment near the operating cable that will create refuges for or increase the rate of growth of bacteria such as Vibrio (specific types found in the Bay e.g., Vibrio parahaemolyticus, Vibrio vulnificus) and E. coli. Oysters and other shellfish that ingest these bacteria pose a human health risk, and monitoring for contaminated shellfish is a considerable state expense. The potential for increasing these risks or cost should be evaluated.
Generally, the submerged portion of this innovative technology presents new issues related to aquatic impacts. As described above, the heat generated from HVDC needs to be quantified as well as the temperature fluctuations at the surface of the bottom. Likewise, the rationale for the depth of submergence and the related tradeoffs need to be fully understood. This includes the expected concentrations of nutrient release due to sediment dispersal and the bottom surface temperature as a function of trench depth. Likewise the methods proposed for trench formation and cable placement need to be properly demonstrated and impacts identified and quantified.
Electromagnetic Field (EMF) issues as impacted by HVDC transmission need to be fully understood and quantified particularly as it may impact benthic biota for the submerged portions and agriculture operations beneath the aerial portions.
Socioeconomics, including impacts to community services –The EIS needs to address the extent to which the project is likely to benefit local labor markets and industries. The application contains little information on labor force requirements, project scheduling, sources of key components, etc., and the extent to which these needs can be fulfilled locally. The Applicants allude to using local labor, but there are no local contractors on the Eastern Shore or in Southern Maryland with HVDC expertise, suggesting the need for imported labor and with it, transient accommodation in an area that experiences large seasonal variations in demand for short-term lodging. Other impacts that need to be considered include potential adverse economic effects on commercial finfish and shellfish fisheries and on recreational water-dependent tourism from construction of the underwater portion of the project in the Chesapeake Bay and construction activities in the Patuxent, Choptank and Nanticoke rivers.
Cumulative Effects - PPRP has concerns about the overall magnitude of affects associated with building the MAPP project and its long-term operation. Whether or not each individual resource impact is acceptable, the sum of all of the impacts may significantly degrade the nature or function of the regional environments of the Western Shore, Chesapeake Bay, and Eastern Shore of Maryland. Further, we believe that it is extremely important for the EIS to consider the effect of creating a new, permanently disturbed, developed corridor bisecting the Bay. Once it exists, this corridor would attract further development over time (it would, for example, become a favored route for additional transmission development under the Energy Policy Act), potentially expanding in width and in the types of bottom facilities and structures present. The effect of a permanent and expandable strip of discontinuous habitat in the Bay, dividing the bottom into upper and lower sections, may include disruption of critical migration routes for benthic creatures and isolation of spawning or juvenile populations from important habitat or other resources. The risk of the MAPP cable ROW developing into such an ecological fence line across the Bay should be seriously evaluated.
Concluding Remarks
We appreciate the opportunity to offer this input into the DOE EIS scoping process and look forward to continue a cooperative relationship as our complementary environmental review processes for this project move forward.
Sincerely,
Sandra S. Patty
Transmission Project Manager
Power Plant Research Program

Tuesday, March 22, 2011

MAPP meeting March 22 US DOE in Prince Frederick

 Get there if you can, with questions!

This is a reminder that the US Department of Energy will host a scoping meeting to obtain public comments regarding its proposed federal action to issue a federal loan guarantee to PEPCO in connection with the MAPP Project.  Members of the public are invited to attend and comment on information to be included in the Environmental Impact Statement to be prepared by DOE.  The meeting will be held at the Holiday Inn Express, 355 Merrimac Court, Prince Frederick beginning at 7:00 pm.  DOE and project personnel will be available for informal discussions approximately 45 minutes prior to the presentation and comment period.

Tuesday, March 15, 2011

Meeting in Dorchester Wed, March 23

What if MAPP were rerouted to pass near your home?
MID-ATLANTIC POWER PATHWAY
VITAL OPPORTUNITY TO PROTECT OUR HOMES
WEDNESDAY, MARCH 23RD, 7:00 PM
CAMBRIDGE-SOUTH DORCHESTER HIGH
SCHOOL
Though we’ve won some major victories, the MAPP extra-high
voltage transmission line still poses a major threat to your home
and mine. In fact, MAPP could still go anywhere in Dorchester
County.
One of the best opportunities to protect our homes, farms,
forests, and waterways happens next Wednesday, March 23rd,
7:00 pm at Cambridge-South Dorchester High School, 2475
Maple Dam Road. That’s when a
public hearing will be held on the proposed MAPP
Environmental Impact Statement (EIS).
The EIS is the only process where all of the alternatives to
MAPP must be given equal consideration, including No
MAPP and routing MAPP around the head of the
Chesapeake along an existing transmission line corridor.
The purpose of this meeting is to take public comment on
the alternatives and impacts YOU want addressed in the
EIS. So we hope you can attend. We also hope you can speak, though this isn’t
absolutely necessary. By simply being one of hundreds who attend the meeting you’ll
send a strong message that we are deeply concerned about this project.
If you do plan to speak then assume MAPP is rerouted so it passes close to your home
or other parts of our County you treasure. Talk about what impacts this could cause
and ask that each of these impacts be addressed in the EIS. Again, at this point
MAPP could cut across any part of our County.
DORCHESTER CITIZENS FOR SAFE ENERGY
4762 RAVENWOOD ROAD • VIENNA, MD 21869 • 410-430-1045 • mapp@ceds.org

Big Questions for Pepco

PPRP Data Request No. 7
Mid-Atlantic Power Pathway (MAPP) Transmission Line Project PSC Case No. 9179
Potomac Electric Power Company (Pepco), Delmarva Power and Light (Delmarva), and Baltimore Gas and Electric (BGE).
7-1 Please provide copies of any and all documents upon which the Applicants' are basing their "understanding that it is necessary to both obtain the CPCN and to start construction on the DC portion of the line by September 30, 2011." (Applicants' February 7, 2011 Motion for Reconsideration). This request includes but is not limited to copies of any and all correspondence between the Applicants and DOE that have formed of contributed to the basis for the Applicants' understanding.
7-2 Please provide the name, title and contact information for any and all DOE personnel or consultants with whom the Applicants' have communicated with respect to the Applicants' understanding that construction must have started on the DC portion of the line by September 30, 2011, in order to obtain a waiver of DOE's loan application fee.
7-3 Have the Applicants asked DOE to extend the date by which a waiver of the DOE Application fee may be obtained? If yes, please provide copies of any documents seeking such a request, the identity of the DOE contact(s) with whom the request was made, and DOE's response.
7-4 Please identify the date on which the Applicants first understood that construction on the DC portion of the line would need to start by September 30, 2011 in order to obtain a waiver of the DOE loan guarantee application fee. Please provide copies of any and all documents that provide a basis for the Applicants' response to this request.
7-5 Please provide a copy of the Applicants' application to DOE for a loan guarantee with respect to the DC portions of the MAPP Project.
7-6 Applicants' February 7, 2011 Motion for Reconsideration, at page 2, states that the DOE application fee "could be as high as $50-75 million." Please provide copies of any and all documents that form the basis for this assertion. Applicants state the fee "could" be as high as 50-75 million. What is the full range of the potential fees for the loan guarantee that the Applicants' have applied for, and what are the factors for determining the actual amount of the fee?
7-7 What is the Applicants understanding with respect to how long it will take to complete any necessary NEPA review process related to the MAPP project before construction can commence. Please provide copies of any and all documents that form the basis for this understanding. Please provide the name, title, and contact information for any DOE personnel or consultants with whom the Applicants have communicated with respect to their understanding of the timing necessary to complete the NEPA review process required prior to construction can commence for MAPP.
7-8 Have the Applicants had any communications with PJM regarding any effects on the current in-service date for MAPP due to PJM's most recent load forecast, or for any other reason? If so, please provide a summary of any such communications and copies of any documents related thereto.
7-9 The Applicants February 7, 2011 Motion for Reconsideration asserts that PJM has performed a capacity benefit analysis based on the results of the May 2010 PJM auction and determined that "construction of only the Possum Point to Chalk Point segment will result in reduction of capacity costs approaching $100 million in the Southwestern Mid-Atlantic Region." Please provide copies of any and all PJM or other analysis that Applicants are relying upon to support this assertion.
7-10 Page 90 of William Gausman’s direct testimony states that the design for the Direct Current (DC) system is in the preliminary stages and that the final cable design configuration will be chosen to carry the required ampacity and minimize EMF and will be finalized once a DC vendor has been selected.
a) Has a DC vendor been selected for the MAPP Project at this time? If not, when do the Applicants expect to finalize the selection of its DC vendor?
b) Has the DC system design for the MAPP Project, including cable type and sizing, been finalized at this time? If not, when do the Applicants expect to have the DC system design completed?
c) Please describe how the cable sizing, rating, and operational design are conducted for the submarine and underground DC cables. What information and specifications has been supplied or will be supplied by the Applicants to the DC vendor? If cable design information has already been provided to a potential or selected vendor, please provide a copy of this information.
7-11 Page 66 of William Gausman’s direct testimony states that the MAPP project will likely be the highest voltage, highest capacity VSC DC
submarine cable system in the world. Furthermore, in the December 20, 2010 Atlantic Wind Connection (AWC) Project filing with FERC, it is stated that the ± 320-kV DC cables proposed for the AWC Project will be 50% higher in both voltage and current than the highest rated cable currently in-service (± 200-kV DC).
a) Does the HVDC cable technology that has been proposed for the MAPP Project currently exist, i.e., has it been manufactured, installed and tested? If so, please provide all examples of such installation, including location, cable size, length, capacity, and operating parameters.
b) If the proposed HVDC cable technology does not exist at this time, please describe the assurances the Applicants have that this advanced technology will perform as predicted and be reliable. Include vendor guarantees, Gantt charts, and supporting manufacturing, testing, and deployment timetables to support the Applicant’s claim that the MAPP Project can be constructed, tested, and fully functional to meet the stated project schedule.
7-12 Exhibit WMG 1-1 to William Gausman’s direct testimony shows a schedule for the MAPP Project, which includes the construction of the Possum Point to Chalk Point portion of the project together with the Potomac River crossing. This schedule shows that Phase I of this construction commenced on January 21, 2011 and Phase II begins on September 16, 2011. Please describe what Phase I and Phase II construction entails for the Potomac River crossing.
7-13 Exhibit WMG 1-3A to William Gausman’s direct testimony is a conductor study for the MAPP Project overhead DC transmission lines. Has a comparable study been conducted for the underground and submarine DC cables that will be included as part of the MAPP Project? If so, please provide a copy of any such studies. If not, please indicate if such a study will be conducted and when the results of this study can be provided.
7-14 Page 2-26 of the Environmental Review Document for the Chalk Point to Maryland/Delaware State Line states that there are standard techniques for the monitoring and mitigation of frac outs associated with horizontal directional drilling (HDD), and that the applicant will be developing a frac out monitoring plan in conjunction with the selected HDD vendor. Accordingly, please provide the following:
a) A detailed description of the standard techniques used for monitoring and mitigation of frac outs.
b) A copy of a frac out monitoring plan comparable to that which will be developed for the MAPP Project. If such a plan does not exist or is otherwise unavailable, please provide a typical plan outline with a detailed description of the contents for each section.
7-15 Page 2-26 of the Environmental Review Document for the Chalk Point to Maryland/Delaware State Line states that the selected HDD depths would be sufficiently deep to avoid pressure-induced frac outs and would primarily be determined using the thickness and porosity of the sediment overburden. Please provide the calculations and/or a detailed description of the method that will be used to determine target drilling depths for the MAPP Project installation on the Western and Eastern Shore Landings. In addition, please provide an estimated range of projected drilling depths.
7-16 The materials provided with the Supplemental CPCN application did not include geographically referenced digital spatial data for the preferred route from the Choptank Landing to Gateway Converter site.
a) Please update the response to PPRP Data Request I-25 to provide spatially accurate Geographic Information System (GIS)-compatible data layers of the preferred route in this segment.
b) The proposed route between Choptank Landing and the Gateway Converter would require constructing a new transmission right-of-way (ROW). Please identify and provide, in GIS-compatible digital format, geographically referenced data for any temporary or permanent access roads that Applicants plan on building to prepare and maintain the ROW, and to construct the transmission line.
c) If any data requested in this question are not currently available, please explain why it is not currently available, and indicate the earliest date such materials will be provided.
d) Please update Applicants’ response to PPRP I-25 to include all additional segments, facilities, or modifications specified in the Supplemental Application, including, but not limited to, the Chestnut Converter Station, Chestnut Converter Station to Western Shore Landing, Western Shore Landing to Choptank Landing, Gateway Converter Station, Gateway Converter to Vienna, and Gateway Converter to MD/DE State Line.
7-17 The Applicants used a variation of the ERPI/GTC Transmission Line Siting Method (see EPRI-GTC Overhead Transmission Line Siting Methodology, EPRI, Palo Alto, CA and Georgia Transmission Corporation, Tucker, GA, 2006) to determine the preferred route for the Choptank
Converter ROW. The first element of the EPRI-GTC method (refer to Macro Corridor Analysis, Appendix C-2 of the Chalk to Delaware Line Environmental Review Document) was not included in the development and definition of the study area for the Choptank Landing to Gateway Converter, as shown in Appendix C-5, page 8, Figure 1.
a) A Macro Corridor Analysis, conducted in the manner of the EPRI/GTC study, may have resulted in a larger study area that included more lands to the north and east of the Goose Creek starting point. Please explain why this preliminary screening was not conducted.
b) Please clarify the data layers and analysis criteria that contributed to the delineations of the boundaries of the study area (Appendix C-5, page 8, Figure 1), particularly the alignment of the northern border.
7-18 The following questions apply to the analysis presented in Appendix C-5, Part IV, Engineering Environment. This analysis eliminated from consideration a number of options, including rebuilding an existing transmission line, co-locating with an existing transmission line, and locating parallel to a road corridor.
a) In Appendix C-5, Part IV, Section 2, page 30, the Applicants claim that "there is no rebuild opportunity in this application." Please explain what efforts, if any, were made to investigate the potential for locating some or all of the proposed new MAPP transmission line within an existing transmission ROW in the study area, such as the Vienna to Steele 230-kV ROW, and the results of those efforts. If no efforts were made to investigate re-build or co-location opportunities, please explain why. If any such efforts were made, please identify the name, title and contact information of the person(s) with whom the Applicants communicated on the above identified issues, and any documents related to such communications.
b) In Appendix C-5, Part IV, Section 2, page 30, the Applicants claim that "The Engineering Environment model gives low suitability to locating a new transmission line within a linear infrastructure right-of-way." Counter to this statement, in the Maryland Tailored Model Figure 6, (Appendix C-5, page 22) the model parameter to rebuild an existing transmission line is given a 1 (highest priority). As seen in Appendix C-5, Part IV, Section 5, Table 4, page 33, the Applicant opted to remove existing transmission line ROWs from
model analysis. This decision removed the potential for locating the new line within an existing transmission line ROW from all model scenarios. Please explain the decision to prevent the model from considering co-location of transmission lines.
c) In Appendix C-5, Part IV, Section 5, page 33, the Applicant states that "roads are not considered as co-location opportunities for this project." The model layer removed from consideration, as seen in Table 4 on the same page, was parallel Roads (not co-located roads, which were retained). If retained, features in this layer would have received a value of 3.6 (moderate suitability) as shown in the Maryland Tailored Model Figure 6, (Appendix C-5, page 22). This removal affected every Alternative Corridor assessment. Please explain the rationale for removing the parallel Roads layer from consideration in all model scenarios.
7-19 In Appendix C-5, Part III, Section 4, page 25, the Applicant states that alternate routes were not generated or evaluated for the new overhead transmission line ROW between the Choptank Landing and the Gateway Converter.
a) Please explain why no alternate routes were considered for this new overhead ROW segment in the Applicants CPCN application.
b) Do Applicants intend to supplement their application with an alternative route analysis for this segment of MAPP? If yes, please identify the earliest date by which Applicants intend to do so. If no, please explain Applicants’ rationale for declining to do so.
7-20 The Maryland Tailored Model Figure 6 (Appendix C-5, page 22) addresses the way the original Georgia feature weights were adapted to Maryland.
a) The Model includes pecan orchards as a feature - a remnant of the Georgia EPRI study (with a high-avoidance rating (9)). Pecan orchards are not a common feature of the Maryland landscape. Please clarify whether there is a similar high-value crop or other agricultural product grown on the Eastern Shore of Maryland which was identified to receive an equivalent low-suitability score.
b) Dorchester County includes in its agricultural areas farms that produce hogs and chickens for the food market. Please explain why these farming areas were not segregated out as features to receive low-suitability scores in the model.
c) The Maryland Tailored Model indicates that Maryland's Green Infrastructure areas were assigned a 2 (high-suitability) as a feature in the Protected Lands layer in the model. Green Infrastructure areas are state priority areas for maintaining or restoring contiguous areas of ecologically valuable forest to conserve natural resources and protect environmental quality. Transmission line ROWs are specifically designated in the Green Infrastructure Assessment as detrimental features that fragment contiguous habitat and create corridors for undesirable invasive species. Please explain how and why the Applicants decided to assign this network of sensitive Maryland lands a score of 2.
7-21 A comparison of Appendix C-5, Part III, Section 2, Figures 5 and 6 (pages 21 and 22, respectively) reveals that the layer weights did not change from the EPRI-GTC model to the Maryland Tailored Model (except for slope, which was removed and the weights re-allocated evenly among the two remaining layers).
a) Were Maryland stakeholders, such as State and local agencies, governing bodies and community/citizen organizations and other such groups, consulted in deriving the weights for the Maryland Tailored Model?
b) If Maryland stakeholders or stakeholder groups provided input for deriving the weights for the Maryland Tailored Model, please provide a list of the stakeholders or stakeholder groups and the methods by which the input was obtained, including dates of meetings, mailings, or other contact methods used.
c) Please provide the results of any stakeholder input activities and indicate the calculations or methods used to derive the final layer weights for the Maryland Tailored Model. In particular, please explain how the final weights, in every instance, ended up being the same as presented in the original EPRI-GTC model based on input from Georgia stakeholders.
7-22 In Appendix C-5, Part III, Section 2, the Applicant did not explain how the Alternative Corridor approach would take into consideration elements within the same layer that may overlap. For instance, in Appendix C-5, Part V, Section 6, page 47, the Applicant states that the FID habitat data and the Sensitive Species Project Review Area data were merged to make the Potential Habitat layer. It is possible that these two data sets may have overlapped in some areas before being merged. Please clarify how such overlapping resource conditions were accommodated in the siting
process, and what degree of attention these situations received in adjusting the route.
7-23 As shown in the Appendix C-5, Part VII, Figure 44, page 61, The Natural Environment Alternative Corridor crosses a large Wetland of Special State Concern associated with the Chicawicomico River north of Route 50.
a) Was an alternative route considered, within the study area that passed through high-suitability areas to the north and east of the Wetland of Special State Concern?
b) If such an alternative was not considered, please explain why. If it was considered, please explain why it was rejected and provide any basis relied upon for doing so.
c) Does the Applicant consider a Wetland of Special State Concern a suitable location for the new transmission line ROW? If so, please explain the basis for this conclusion. If not, please explain why the area in question was not marked as an excluded area so that the Natural Environment Alternative Corridor would have avoided it.
7-24 The Vienna-to-Gateway portion of the preferred route is located for about a mile in the 100-year floodplain of the Nanticoke River, based on a visual inspection of Appendix C-5, Part V, Figure 17, page 34. The floodplain is given a value of 9 (low suitability) in the model (Maryland Tailored Model, Appendix C-5, Figure 6, page 22).
a) Given that this floodplain was given a value of 9 (low suitability), please explain why the Applicants have nonetheless selected a route through this floodplain area. Please provide all studies, documents, reports and any other documents that provide the basis for the Applicant’s decision to route the transmission line across this 100-year floodplain that has been classified as low suitability.
b) Please describe and provide copies of any studies that have been conducted to determine the effects of the proposed project on future flows in this area. If no such studies have been conducted or consulted, please explain why not. If such studies will be conducted, please explain when they will be made available.
c) Please describe the construction and maintenance procedures that the Applicants will use to minimize damage to the floodplain area.
d) Please indicate whether the Applicants’ considered any potential increased flood frequency anticipated due to climate warming.
7-25 As seen in Appendix C-5, Part V, Section 4, Figure 28, page 44, the Vienna-to-Gateway portion of the route passes through two Critical Area buffer zones (land within 1000 meters of tidal waters and associated tributaries), and yet the water area between the Critical Area polygons is considered open land in the Natural Environment scenario (Appendix C-5, Part V, Section 5, Figure 30, page 46). The tidal waters of the Chesapeake Bay and its tributaries, and the lands below them, are by definition part of the Critical Area. Therefore, the part of proposed route between Vienna and the Gateway Converter includes approximately 1.8 miles of contiguous Critical Area buffer, riverine, and water/wetland habitat.
a) In light of the above statement, please provide a corrected assessment of the amount of Critical Area affected by the proposed route. Please indicate how this correction with respect to the amount of Critical Area affected by the proposed route, will affect the assessment of the impacts of this portion of the route. If Applicants disagree with anything in the above statement with respect to the Critical Area, please identify the disagreement and the basis for it.
b) Do the results of this re-assessment change the feasibility or cost of siting a transmission line between Vienna and the proposed Gateway Converter site?
7-26 In Appendix C-5, Part VIII, Section 3, the Applicants claim that "Contrary to the Natural Environment, the dominance of agricultural areas in the study area is seen as a siting opportunity in the Built Environment."
a) Please explain this supposed contrast, in light of the fact that agricultural lands are also considered a siting opportunity in the Natural Environment analysis: they would get a 1 (high suitability) in every layer, except Land Cover where pasture and row crops are separate but both also highly preferred.
b) Please explain why "Built Environment" siting opportunities, such as parallel roads and existing transmission line ROWs, were removed from the "Natural Environment" analysis.
7-27 In the Applicant's ERD (Chalk Point to the Maryland/Delaware line), Section 3.2.3, page 3-5, the Applicants claim that a cost threshold was applied in the analysis for the Western Shore Landing to the Gateway Converter site portion of the project (section 3.2.3) and the cost of alternatives was included as a criterion in every scenario.
a) Please specify the cost threshold value.
b) Please indicate how the cost was determined for the Alternative Corridor analysis in each Environment.
c) Please specify at what point the cost threshold was applied and how it affected the Alternative Corridor analysis in each Environment.
d) Was the cost of mitigating for environmental impacts, such as the loss of conserved natural resources or environmental quality, included in the cost calculation for each alternative? If so, please indicate how these costs were calculated. If not, please explain the reasons for not including these costs.
7-28 According to the ERD, Section 3.4.2.1.3, page 3-71, the Open House held in Dorchester County on May 12, 2010 was the only Open House that presented the Applicant's preferred route to the public. Please summarize the comments received at or in reference to this one meeting and identify areas of the route that were modified in response to the feedback obtained at the meeting.
7-29 Please identify and describe where 290.1 acres of Maryland's Targeted Ecological Areas (ERD, Section 4.5.2.4.1, page 4-115) have been included in the siting process that defined the proposed route in the Choptank Landing to Gateway Converter portion of the MAPP project. Please describe what effect the inclusion of this data layer had on the adjustment of the route in this portion of the project.
7-30 In the ERD (Chalk Point to Maryland/Delaware line), Section 4.5.3.4 (Western Shore to Gateway Converter), page 4-121, the Applicant states, "The total acreage of permanent and temporary vegetation that would be disturbed during installation and operation would be determined when Project engineering and design is complete."
a) When will this information be provided? Was it infeasible to complete such information at the time the supplemental application was filed in November 2011? If so, please explain why.
b) Please describe the current status/level of completeness of the project engineering and design for the above referenced segment of the project. Please identify when the engineering and design phase of this portion of the MAPP project is scheduled to be completed, and please provide copies thereof.
c) How long after the completion of the engineering and design phase will a draft vegetation replacement plan, accounting for the forested lands to be cleared (estimated with NLCD data to be in excess of 208 acres), be available for review?
7-31 In the ERD (Chalk Point to Maryland/Delaware line), Section 4.6.3.4 (Western Shore Landing to Gateway Converter), page 4-143, the Applicants state, "The Company and its contractors are currently consulting with MDNR, as needed, to identify impact minimization measures to sensitive species or habitats that may be impacted by Project installation and operation in this component. Please identify the number of such consultations, the date(s) of such consultations, the person(s) both from the company and/or its consultants and from MDNR who participated in such consultations, and please summarize the issues discussed.
7-32 The following documents are cited in the ERD, but are not included in the materials provided. Please provide copies.
a) National Marine Fisheries Service (NMFS). 2009. Letter dated November 4, 2009 from John Nichols (NMFS – Habitat Conservation Division) to Arthur Sanders (ENTRIX) regarding Mid-Atlantic Power Pathway, Eastern Shore Alternatives.
b) NMFS. 2010. Letter dated June 21, 2010 from Mary Colligan (NMFS – Protected Resources Division) to Arthur Sanders (ENTRIX) regarding PHI Mid-Atlantic Power Pathway.
c) USFWS. 2009. Letter from Leopoldo Miranda (USFWS) to Art Sanders (ENTRIX) regarding federally listed threatened and endangered species within the Dorchester County portion of the proposed MAPP project. Letter dated October 6, 2009.
d) The Project consultation letter referenced on page 4-165 ("As of September 1, 2010, USFWS had not provided a response to the Project consultation letter.") and an update of the status of this consultation. If USFWS has responded, please provide a copy of the response.
7-33 The original siting study, Taylor's Island to Vienna, evaluated the ROW along Route 50 (particularly to the southeast of the crossing of the Chicawicomico River) as a viable and preferred path for the transmission line (refer to Appendix C4, Dorchester County Electric Transmission Line Siting Study, Part XI, Figure 64, page 115). The study results for the
Choptank Landing to Gateway Converter, shown in Appendix C-5, also find the Route 50 path viable for the Natural, Engineering, and Average Environments, yet the revised preferred route does not use the ROW along Route 50. Please describe how the preferred route was derived from the model assessments, specifically indicating the criteria that resulted in the decision to avoid siting along Route 50 despite the model assessments.
7-34 The Applicant claims that the extent of impact on terrestrial resources is based on a 200-foot ROW.
a) Please describe the conditions under which the ROW would need to deviate from a width of 200 feet within the proposed route.
b) Does the Applicant maintain that terrestrial resources outside of the nominal 200-foot ROW will not be affected by constructing the new Choptank Landing to Gateway Converter portion of the line ? If the answer is yes, please explain how this will be accomplished.
c) If the answer to (b) is no, please estimate the area of terrestrial resources that will be affected by construction, including the area required for access roads and staging areas for equipment and materials.
7-35 On January 4, 2011, PHI and PPRP representatives had a technical meeting to discuss the scope and status of certain Applicant environmental and socioeconomic studies being conducted and certain engineering designs being completed with respect to the MAPP project. At the meeting, Applicants indicated such studies will be completed by the end of March 2011, and will be made available to PPRP at that time or sooner if available. Applicants also indicated they will be filing a supplemental environmental review document with the PSC to address such studies.
a) Please confirm that Applicants are on track to provide to PPRP the studies PPRP requested at the January 4, 2011 meeting, by the end of March 2011. If such studies will not be provided by then, please explain why not, and identify the date by which each requested study and engineering information will be provided.
b) Please confirm that the Applicants intend supplement their environmental review document filed with the PSC in this case to address the studies discussed at the January 4, 2011 meeting.
c) If any studies requested at the January 4, 2011 meeting are now available, please provide them to PPRP immediately.
d) Please provide PPRP with a copy of the Applicants’ DOE NEPA submittal and joint permit application.

Tuesday, March 1, 2011

MDE Heard from All of Us

We all commented to MDE about Mattawoman and Parkers Creek Watershed

CEDS Comments
Reacting to the largest wetlands impact project in the state’s history, today CEDS called on State and Federal wetland permitting agencies to prevent record-setting environmental impacts that would result from the proposed Mid-Atlantic Power Pathway (MAPP) project in Charles and Prince George’s County.  This massive new power line project not only affects the Mattawoman watershed but also impacts the Potomac River, Nanjemoy Creek, Zekiah Swamp, Piscataway Creek, and the Patuxent River.  The comments are posted under MAPP Wetland Permit at the left-top of the CEDS Transmission Line webpage: ceds.org/tl

At first blush this project seems like no big deal; just adding a second circuit to 52 miles of an existing transmission line corridor.  But a close look at the details paints a very different and alarming picture.

This 52-mile project (which is only half of the overall MAPP route, but is the only portion currently pending before state environmental regulators) is three times longer then the Inter County Connector and twice as long as the next longest transmission line considered in Maryland since at least 1990.  This relatively short MAPP segment would result in the loss of 118-acres of forested wetlands, temporary impacts to another 102 acres of wetlands, and clear-cutting of 260 acres of upland forest.  According to US Army Corps of Engineers records, the forested wetland impacts of this one project are nearly four times greater then that of the next biggest project considered since at least 1991.  The forest loss alone is equivalent to that caused by 135 typical development projects. 

Half to two-thirds of the impacts will occur in the Mattawoman Creek watershed.  This highly regarded waterway has been declining over the years due to a combination of development and forest loss.  The MAPP project will cause a forest loss equivalent to 64 development projects in the Mattawoman watershed, which will accelerate the decline.

Our comments included six alternatives for maintaining reliable and affordable electric service without the massive environmental impact resulting from MAPP as proposed.  The first alternative calls for verifying that MAPP is truly needed.  Declining growth in electricity demand has prompted a delay of MAPP by one year, for every year since it was first proposed.  Yesterday, regional transmission planning organization PJM made a startling announcement that a similar project – PATH – would be put on indefinite delay.  This prompted the applicant to withdraw their request that the Maryland Public Service Commission issue a Certificate of Need & Public Necessity for the project.  PJM will be releasing an updated analysis of the need for MAPP in a few weeks.  It is anticipated that the in-service date for MAPP will delayed by yet another year if not longer. Changing market conditions throughout the mid-Atlantic region, combined with the likelihood of construction of new clean and local power generation resources and demand-reduction programs have superseded the need for these mega transmission projects.

These are but a few of the many serious issues identified in our comments.  Following is a listing of all of the issues.

  • Summary
    • A Massive Project; Record-setting Wetland Impacts
    • Public Notice Didn't Convey Massive Potential for Impact; Second Hearing Needed
    • Proposed Mitigation Woefully Inadequate
    • Mattawoman to Bear Brunt of MAPP Impact
    • Criteria for Review of Nontidal Wetland Permit Applications Not Met
    • Practicable Alternatives Not Fully Considered
  • Introduction
  • Proposed Wetland Impacts
  • MAPP Impacts Are Record-setting
  • Expanded Public Participation Opportunities Urgently Needed
  • Proposed Mitigation for Wetland Impacts
  • MAPP Forest Loss = 64 Development Projects
  • Mattawoman Creek Bears Brunt of MAPP Impacts
  • Mattawoman Creek: Indicators of a Stressed System
  • Mattawoman Creek & Impervious Area Threshold
  • Mattawoman Creek & Critical Forest Threshold
  • Lack of Compliance with the Non-tidal Wetland Regulations
  • Mitigation Plan Will Not Offset Impacts


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Richard Klein