Thursday, October 03, 2013
Save the Ozarks, in an Oct. 1 filing before the Arkansas Public Service Commission (APSC) in the case of the American Electric Power (AEP)/Southwestern Electric Power Company (SWEPCO) high voltage transmission line said AEP/SWEPCO has failed to prove a need for the facility, the Environmental Impact Statement (EIS) is seriously flawed, and there is not sufficient analysis of the economic impact on the community.
The filing states that AEP/SWEPCO has not obtained or submitted a number of environmental permits required for a new major transmission line, and does not plan to do so until after the commission decides whether to issue the Certificate of Environmental Compatibility and Public Need (CECPN).
“The July 2013 letter to the commission from the Army Corps of Engineers states clearly the position of the federal agency charged with issuing two of these environmental permits, a Rivers and Harbors Act Section 10 permit and a Clean Water Act (CWA) Section 404 permit, that such federal environmental permits are required to be obtained by SWEPCO for the project,” the filing said. “SWEPCO has intentionally not applied for, obtained, or submitted several such permits.”
STO also said there was no analysis of economic impacts on Eureka Springs.
“The only mention of economic impacts in the EIS concerns the lack of any positive economic impacts such as significantly increased local employment due to the project,” STO states. “There is no discussion in the EIS of adverse impacts on tourism, the arts, or other businesses. The proposed AEP/SWEPCO transmission lines are likely to cause significant adverse economic impacts on the local communities through which the lines will pass including Eureka Springs, including significant adverse impacts on tourism.”
STO claims AEP/SWEPCO’s consultant noted that impacts on tourism should have been considered.
STO also believes the application was deficient in providing a good cost estimate of constructing in an area with karst features.
Another flaw STO alleges is there was no assessment regarding whether the proposed project is the most cost effective for ratepayers. “No assessment was done comparing the costs of the proposed project to STO expert witness Dr. Hyde Merrill’s identified alternatives,” STO said. “Operation and maintenance costs were not included.”
STO took issue with AEP/SWEPCO receiving a notice to construct the project from Southern Power Pool (SPP) in 2008, and after finally starting the project five years later deemed it “critical.”
“Case studies were provided by Dr. Merrill that exemplified why the North American Electric Reliability Corp. requires that plans not rely on long-term forecasts,” STO said. “In these cases, the needs were re-evaluated every year, and every year the need became less severe and receded a year. Load forecasts are the most important driver of need for transmission reinforcement. Based on SPP data, demand has been stagnant since 2006. The forecast for 2016 that was made by SPP in 2006 followed years of consistent high demand growth and preceded the stagnant demand since 2006. The load growth projected by SPP… has not materialized.”
After it appeared the initial reasons for constructing the line no longer exist, AEP/SWEPCO testified the line was needed to solve reliability issues for Entergy. But STO said Entergy did not request resolution of a reliability problem in this area, Entergy had not diagnosed a reliability problem here, and Entergy was not trying to resolve a reliability problem here.
STO also alleges the SWEPCO EIS and application have been obvious in failing to address impacts on Corps properties. STO cites a letter from the Corps to the APSC that any impacts to Corps of Engineers property associated with crossing Beaver Lake, Table Rock Lake, or the White River will require a review for National Environmental Policy Act (NEPA) compliance. The Corps also stated any impacts to their property associated with crossing those bodies of water will require a Regulatory Section 10 Permit.
AEP/SWEPCO denies it will need NEPA compliance. NEPA requires more thorough environmental studies, evaluation of less damaging alternatives, and sets a high priority on environmental protection.
“The SWEPCO EIS fails to address erosion and sedimentation issues relating to Corps properties stemming from potential loss of vegetation, loss of Bald Eagle roosting habitat, impacts to cultural resources, and the aesthetic impacts from a 150 ft. right-of-way,” the STO filing states.
“The EIS also fails to address available and feasible alternatives to the project identified in direct testimony of Dr. Hyde Merrill that solve the problem identified by SWEPCO in the application and by SPP in the notice to construct as creating the need. Dr. Merrill’s alternative solutions resolve this prior identified need with dramatically less environmental impacts and at dramatically lower cost. There is nothing in the EIS that provides a counter analysis.”
STO also finds it significant that neither the application nor the EIS addresses the connection of the project to the Entergy system, which SPP and SWEPCO admit is required to complete the project. AEP/SWEPCO also failed to address impacts from or alternatives to the chosen location for the new Kings River substation.
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