The draft environmental impact statement (EIS) for the Susquehanna-Roseland transmission project contains inaccuracies ranging from project cost to environmental impact, PPL Electric Utilities and Public Service Electric & Gas said in Jan. 30 comments.
The companies spent five pages of its 55-page document specifically addressing misstatements about their proposed routes, Alternatives 2 or 2a.
“These mistakes and overstatements often seem to arise from a fundamental failure to acknowledge the character of the existing 230 kV [Bushkill to Kittatinny] Line and the fact that is has been a part of the landscape shared with the NPS Units (and their visitors) since the moment each of them was created,” the companies said.
The 500-kV Susquehanna-Roseland project would use an existing right of way along which the 230-kV Bushkill-Kittatinny line is routed, the companies pointed out.
Among other things, the draft EIS overestimates the cost of construction for Alternative 2 at $2.17bn, compared to the companies’ estimate of $1.25bn. Contributing to the National Park Service’s estimate are the assumptions that there will be 11 towers per mile, instead of 5 towers per mile; that shield wire will cost $3/ft. as opposed to $1/ft.; that the per-mile cost of optical ground wire is $17/ft., compared to $2/ft.; that the cost of conductor wire will be $3m per mile, compared to $150,000 per mile; and that the cost of ROW acquisition is $100m, compared to actual costs of $3.4m in Pennsylvania and $21.3m in New Jersey.
The draft EIS states that the proposed right of way (ROW) for the project would bisect the Hogback Ridge Woodlands, creating two sections of Woodlands and reducing interior forest habitat. However, the Bushkill-Kittatinny line already bisects that habitat, meaning the proposed project would have no additional impact on the environment, which the draft EIS fails to acknowledge, the companies said.
With respect to visitor use, the draft EIS does not properly take into consideration the existing transmission line, which “has been in place in the NPS Units from the moment of their creation” and has not detracted from visitor enjoyment.
“The incremental impact of the construction of the S-R line should not change this dynamic and the only direct impacts to visitor use that are substantially different to what exists now would occur during construction when there will be more physical activity within the ROW,” they said, adding that since construction on the line will be limited to the winter months, visitor volume and thus visitor impact will be much lower.
“The DEIS should be revised to inform the decision-maker and the public that the existing transmission line and corridor through the [Delaware Water Gap National Recreation Area] is itself considered a historic component of the existing visual environment and cultural landscape,” they said.
With respect to access roads, the draft EIS “mischaracterizes” the amount and character of the existing access roads associated with Alternative 2, as existing access roads within the existing ROW will largely be used for the line’s construction. Of the seven acres of new proposed roads, only 0.5 acres would require new construction outside the existing ROW, the companies said.
Furthermore, after “informal consultations” with the National Park Service and the United States Fish and Wildlife Service, the companies proposed an alternate access road south of the Arnott Fen, which would have no impact on the Fen and would result in 0.4 acres less of road impacts, they said.
The draft EIS assumes that a 350-ft-wide corridor would have to be cleared, but the companies’ proposed route would require only an additional 50 ft. of right of way (ROW) along a 0.76-mile section that currently is only 100 ft. wide.
“Therefore, it is legally impossible for the Applicants to clear a 350 feet ROW contemplated as by the DEIS,” they said.