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

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