Anita Masters
Submitted Via
Email
RE: Comments on the draft Environmental Assessment
of the “Aspen Grove-Bingham 161-kV Transmission Line,
Dear Anita
Masters:
This letter comprises the comments of
the Harpeth River Watershed Association on the draft EA for the proposed 161-kV
TVA transmission line to connect Aspen Grove substation to a proposed Bingham
substation. Our organization has been
working with TVA and Middle Tennessee Electric Membership Corporation (MTEMC)
since mid-2001 on this proposed project.
The HRWA first communicated our concerns regarding the proposed route’s
potentially significant impact on water quality in July 2001 not long after
this route became a working proposal from TVA.
Our 4-page comments are in Appendix I of the draft EA.
Since
then, we have worked with the Heritage Foundation, the
I.
Comments on Need and the Alternatives
With
the growth in the
The
Bingham Service Area and Load Growth: The Draft EA does not adequately define the
Bingham service area. According to a map
provided to us by MTEMC during the Synapse Energy Economics analysis process,
the Bingham service area is practically all rural. It includes a portion of western
Energy Efficiency
Alternatives: Though the draft EA
briefly describes TVA’s current energy efficiency programs, these are all
voluntary as are those of MTEMC. This EA
is not adequately considering the contribution that efficiency can make to
addressing load growth, distribution power generation, and other options that
could be put in place immediately and over time. This EA is based solely on electrical
transmission, distribution, and system upgrades, not on any demand side
management. Synapse Energy Economics
references that the US Government Accounting Office completed a study of TVA’s
demand side management and found them lacking relative to other utilities
(Attachment 2).
Synapse Energy Economics also
conducted an analysis of the energy efficiency potential in
Even
though this study could not be very specific to Williamson County because of
the lack of county specific data available to Synapse, the electrical needs in
this region can be addressed with a combination of energy efficiency and
infrastructure improvements that would reduce the cost to rate payers and enable
the important cultural, environmental, historic, and aesthetic values of this
region to be maintained. The HRWA, SACE,
Southern Land Company and the city of
Other
Alternative configurations for transmission lines and substations:
As described in our joint comments to TVA on
Option
A is viable and there appears to be time: With the Bingham
substation in its proposed location and option B for the TVA line as proposed,
then the logical next project appears to be to build the TVA line connection
along Option A back up to the Davidson Substation to make the 161-kV loop and
get the third feed into the county. The
draft EA notes that this option is not timely because of the risk that the
National Park Service may not permit the expansion of the existing minimal
crossing of the
It
appears that the sense of urgency to relieve the Aspen Grove substation is
driving the choice of Option B. Yet,
according to Appendix I, page 2, if tie ins are made between existing
substations, then the existing system can spread the load and Aspen Grove will
not reach capacity in 2004 as in the chart (which is based on no tie ins). Instead Aspen Grove will not reach capacity
until 2006 or even as late as 2010 because MTEMC is actively upgrading its
system.
It is also worth noting that though
the costs in the 1999 One Owner study would need to be updated, at that time
the alternative to do distribution system upgrades versus a new substation and
a TVA line were almost identical in total costs. Distribution system upgrades were estimated
at $11.3 million, and building the Bingham substation was estimated at $5.3
million. When the cost of the TVA line
that has been estimated at $5.9 million is added, there is really no difference
in total cost. What is different is
MTEMC only needs to spend half what it would if it did all system
upgrades. So, the proposal for a TVA
line is not a cost savings to the rate payer.
Alternatives to Option B and a
planning process: There are clearly
alternatives to running the proposed transmission line along Option B, then
building another transmission line along Option A. The important next step would be for TVA to
work with this community to pilot a more meaningful, engaged transmission
planning process. We would suggest that
TVA look into using the transmission planning process similar to the one
recently developed by a similar entity, Bonneville Power Administration. Through this process, which includes energy
efficiency, TVA and MTEMC would be able to define an infrastructure system with
the community and avoid delays as has been experienced with this proposal.
We believe that there are some more
appropriate options that Option B.
Though the HRWA does not endorse any of these, we would be willing to
work as part of a planning process with TVA and MTEMC on considering these and
others. These below do not include
energy efficiency and load distribution options that are described in the
comments submitted by SACE. For example:
- Consider building the TVA line on
Option A to the proposed Bingham substation now, and run distribution
lines from Bingham back to the high growth area of
- Consider building a new substation
along the Option B corridor much closer to
- Consider making a 161 k-V loop by
using Option A to a Bingham substation, then continuing south along the
same Maury-Davidson 500 kV Line and coming across the short distance in
the southern part of the county to the Maury-Radnor 161 kV line. This route between the two lines could
follow the SR 840 right-of-way.
II.
Comments on Environmental Consequences and Mitigation:
The
HRWA is opposed to using Option B. It
appears that any of the proposed routes in Option B will have significant
effects to water quality, historic and cultural resources, and viewsheds of
importance to the county and city in their planning. The Bingham substation location makes it
impossible to site a route that doesn’t significantly adversely impact historic,
scenic, archeological or cultural resources or contribute to degradation of
river systems. As outlined in the
section above, the HRWA believes that there are other options to this proposed
line in this corridor.
Preferred
route of Option B has the most river crossings and a lengthy floodplain
corridor:
The
HRWA already submitted extensive comments regarding the negative effects on
water quality and riparian corridors from the proposed route (see Appendix II). These here are additional comments. It appears that when TVA was considering
which of Options A-D to pursue, the effect on river systems was not even
considered. The draft EA does not even
list the need to cross the Harpeth and West Harpeth as siting constraints for
Option B (p. 16). Not only does the
proposed route have the maximum river crossings, the need to construct access
roads is a vital issue with the proposed route going along the West Harpeth
riparian corridor and along the main Harpeth corridor.
To add reference data to our comments
on July 2001, I have attached the summary report of the Volunteer Visual Stream
Assessment report that was conducted in the Harpeth on the state designated
impaired streams with funds from the TN Department of Agriculture’s NonPoint
Source Program (Attachment 4). There are
a number of sites surveyed with poor riparian habitat and unstable banks that
are under transmission and distribution lines.
Here is an image on the West Harpeth where a 500-kV line crosses just
south of the proposed multiple crossings for this proposed 161-kV line. Active bank erosion and no bank vegetation is
a common sight for line crossings throughout the watershed, and are active
sites of erosion.
Figure 1: Maury-Davidson 500-kV transmission line
crossing the West Harpeth near Old Boyd Mill and
In
addition, the final technical report is complete on the two year sediment study
on the Harpeth. This study has helped
quantify the amount of sediment loss in the upper half the Harpeth and indicates
specific streams with erosion problems. There
were five study sites on the West Harpeth (see Attachment 5). Data from Table 4-1 of this sediment study shows
that the site at the confluence of the West Harpeth and main Harpeth is
possibly as much as 5 times more turbid that the site upstream at Leipers Fork,
a tributary on the West Harpeth. Many
actively eroding banks are a source of this sediment load based on the Visual
Stream Assessment survey, and the preferred TVA route will add 10 more exposed
streambanks. There was also a sediment
study site on the main Harpeth downstream of the proposed TVA crossings and
before the confluence of the West Harpeth that documented high turbidity.
The
draft EA states on page 37 that the various alternative routes are not
different in their affect on water quality.
This is hard to justify when alternative C would eliminate many
On
the visual impacts of the line, the draft EA is incorrect in assuming that the
5 crossings of the West Harpeth would not affect the view. Many people in the area enjoy canoeing this
section of the West Harpeth because it is easy to gain access not far south of
the proposed substation and egress where the West Harpeth joins the main
Harpeth. Multiple line crossings and
canopy openings will definitely affect the view from the river.
Mitigation
proposed is not adequate
We
are glad to see that the draft EA gave consideration to how to mitigate for the
numerous river crossings. However, we believe
that the mitigation offered in draft EA in section 4.4 on Aquatic Ecology, in
Appendices IV-VII, and elsewhere is not sufficient to make the determination
that the proposed route with the most river crossings would have insignificant
impacts. The mitigation proposed would
involve TVA resource stewardship staff consulting on the construction design
and making recommendations for native plantings and other means to provide bank
stabilization. But, it appears that all
the project control is with the Transmission Construction department. The reality is that all the mitigation and
oversight is within TVA and that even with best laid plans, proper implementation
is the key. If there is not very active
oversight and involvement that includes outside and locally based expertise, during
design, construction, re-vegetation, and active efforts with land owners, it is
highly unlikely that this proposed route will end up with 18 stable stream
banks with good vegetation stream buffers.
The
other mitigation mentioned in Appendix VI was that all intermittent and
perennial water courses be designated as Level B, Protection of Important
Permanent Streams. The two additional
requirements this involves from the standard level of protection is to reduce tree
cutting to just those that are considered dangerous to the infrastructure, and
that proposed crossings will be discussed in advance with TVA resources Stewardship
staff and require on-site planning. This
Level B designation could help, but it will not amount to much if the
contractor does not actually follows through with the plans.
Predominantly the draft EA give little
indication that the construction and vegetation management of the line corridor
will be anything other than current practices.
Yet, it is precisely current practices that are the reason for water
quality problems at line crossings. The mitigation language refers to the Guide
by Muncy, “BMPs for TVA Transmission Line Construction and Maintenance.” It is great to see that TVA has a guide, but
it is more important that the contractor is very qualified and has a good track
record. Giving a contractor this manual
is no guarantee for appropriate work.
Though
the guide was updated in 1999, there is little if any mention of use of native
plantings or low growing shrubs in the stream management zone. Several figures do not depict adequate
erosion control plans such as Figure 2 for access roads. This guide only refers to stream crossings
for equipment of banks up to 5 feet high.
This is lower than the banks on the main Harpeth. Also a major weakness with the initial reseeding
of bare soil after construction is lack of follow-up. This is where contractors tend to cut
corners.
Vegetation
re-clearing plans are described in the draft EA as being the typical regime of
mechanical mowing and herbicide use that is intended to maintain not much other
than grass. The missed opportunity and
problems with these re-clearing plans are an issue in TVA territory as noted by
the work of the Public Lands Subcommittee of the RRSC to establish a policy on “TVA
Transmission Line Rights-of-Way Maintenance Policies and Practices.” This policy is intended to encourage more
attention to existing re-clearing and opportunities to work with land owners to
use native species, improve habitat integrity, and consider wildlife benefits in
the rights-of-way. The draft EA noted
the presence of invasive species in this region. So there is an opportunity with the
vegetation plans to use native plants that not only need minimal management (re-clearing),
but would also help with restoration of terrestrial and aquatic habitat
quality.
Another
example of lack of effort to move beyond current “business-as- usual” for line
construction and corridor management is that the restoration of all disturbed
sites is simply to establish grass cover. There are many options that would be
appropriate to use and it would also mean that the construction contractor is
not likely to be the best to do the restoration plan. In addition, it would be best to avoid
burning the cleared vegetation that is a typical practice as described in the
draft EA. This cleared vegetation can be
converted to mulch and used an effective sediment control barrier. Mulch is also used as an erosion mitigation
measure for cover for a bare site.
Mitigation for the effects of so many
river crossings and running along the West Harpeth riparian corridor will
require a combination of actually re-aligning the route to reduce crossings and
a real commitment of additional funds and incorporation of outside (non-TVA) expertise
in many aspects of this project. Though
there are many qualified TVA personnel, non-TVA and locally based experts in
the process will provide a check and balance.
Outside expertise and local expertise would need to be involved in siting
the center line and low points, siting pole location and number of poles, and
designing access roads among other things to minimize impacts. Involvement by non-TVA and local expertise would
also include identifying sensitive areas for special treatment, the design for
sensitive areas, the vegetation removal plan, on-site planning,
pre-construction review, re-clearing plan, Erosion and Sediment
Control/BMP/Stormwater Control Plan, ARAP permit, and related issues. An effective process to stop work if there
are violations would also need to be delineated. In addition, there would need to be a focus
to avoid stream crossings for equipment as much as possible.
Local
involvement would be critical to enabling TVA to facilitate efforts by local
landowners to undertake restoration efforts on the affected rivers. These efforts would compensate for the TVA
line crossings by improving stream conditions within the same sub-watershed. TVA funds to cover these projects can
leverage other funds for watershed restoration.
As a result of the above comments, the costs of the proposed TVA
transmission line will go up considerably to address how the proposed route
would not further degrade aquatic resources.
If
any TVA staff have any questions regarding these comments, please do not
hesitate to contact me.
Sincerely,
Dorene Bolze
Executive
Director
615-591-9095
Dorie@DorieBolze.com
List of Attachments sent as separate
E-mails:
- HRWA Resolution of the Board,
dated
- Memo from Synapse Energy
Economics,
- Report prepared by Synapse Energy
Economics,
- Volunteer Site-Specific Visual
Stream Assessment of 303(d)/305(b) Listed Streams in the Harpeth River
Watershed: August 2001-December
2001. Conducted the by the HRWA.
- Dr.