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.

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.

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

-----------------

Richard Klein