Saturday, March 23, 2013

Clean Line Energy, FERC, Section 1222, and EIS

FERC recently has asked for comments on what should be included in an environment impact study for their venture politics endeavor with the vulture capital funded Clean Line Energy with the Plains & Eastern Clean Line Project.

With Arkansas rejecting "Clean" Line Energy's application for public utility status, the company is working towards federal eminent domain through Section 1222 of the 2005 Energy Act.  To my knowledge, this has never been used before for federal eminent domain.

As a part of the process FERC has opened up for comments from the public on what should be included in an Environmental Impact Study.  Below is the letter I submitted to FERC in this matter.

Clean Line Energy’s Plains & Eastern project being proposed in conjunction with FERC in regards to a potential Environmental Impact Study has created some concerns.  
First, the environmental impact of comparable projects to bring renewable energy should be considered.  There are always alternatives and other options, such as bringing offshore wind energy from the Atlantic into this market.  While the Plains & Eastern Clean Line (P&ECL) option is traveling 750 miles to bringing the energy to the west end of the market, how much environmental impact would a shorter transmission line cause to bring energy to the eastern end of the same market? 

Distributed Generation, Demand Response and Energy Efficiency initiatives should also be reviewed as potential alternatives and the environmental impact of these options should also be reviewed.  New England ISO has shown great results from Energy Efficiency initiatives with no negative impacts to the environment.    

There are clearly economic alternatives.  It is not within the scope  of an environmental impact study to evaluate the economics of the alternatives,  but the environmental impact of those alternatives are relevant and need to be reviewed.  Perhaps the alternatives will bear a milder impact to the environment and show that a different course of action should be considered by FERC.
Also, Clean Line Energy has claimed this project will provide 5,000 temporary jobs and 500 permanent jobs.  This kind of economic modeling is taking into account all the jobs of the multiple wind farms plus any ripple effect allegedly created by the supposed economic benefit of this transmission line and wind farms in the surrounding communities.  This same approach should be applied to an environmental impact study.  While this project is just a 750 mile transmission line that can cover approximately 18,000 acres of right of way, P&ECL will also create wind farms that can cover a 200 square mile area.  

Whether this is 200 square miles of one big wind farm, or 200 square miles of a collection of smaller wind farms cover an even greater area, 200 square miles is still 200 square miles.  This estimation of 200 square miles is based on 2MW windmills and using 65 acres per windmill.  Over populating windmills less than 1 windmill per 65 acres will also create a larger environmental impact.

200 square miles of wind farms in Oklahoma and Northern Texas will have an environmental impact including a warming effect in that community.  Bird deaths from a 200 square mile wind farm should be accounted.  Winter migrations should also be accounted.  Bird species in this area should be known and considered, especially bald eagles.

Finally, the EPA has identified environmental justice as being a necessary component of an environmental impact study.  The EPA recognizes projects such as P&ECL historically take the path of least resistance.  Consequently whether the project is a refinery, coal mine, or transmission line, these projects tend to migrate towards economically depressed areas and avoid the resistance of wealthier and potentially more knowledgeable areas, where the public has a greater means to oppose such projects.  

With projects, like P&ECL, going through economically depressed areas, there is a compounding effect on the environment.  Future positive projects, such as tourism, will migrate away from P&ECL and more negative projects that are more harmful to the environment will be drawn closer to areas near Clean Line Energy’s transmission line as a 750 mile magnet.  The EPA recognizes those people living in these areas will have a more difficult time developing out of the economic disadvantage and the environment will suffer more.  

With Clean Line Energy’s offer price of $2,300 per acre for the Right of Way, this is clearly an economically depressed area.  Even with limited knowledge of transmission Clean Line Energy’s starting price for right of way’s in Illinois is more than three times greater the price the company is offering for landowners along P&ECL.  It is also known energy companies in Illinois have paid far more than what Clean Line Energy is offering in Illinois for right of ways.  Northern Pass is offering even more in New Hampshire.  For P&ECL to offer only $2,300/ acre for a right of way shows this is an economically disadvantaged area of the nation.  For FERC to complete an environmental impact study here, a proper review of Economic Justice as described by the Environmental Protection Agency needs to be done.  

Furthermore, the Environmental Protection Agency should be consulted on this matter and their opinion and approval should be sought.  Going back to the example mentioned above of potential other sources of renewable energy, will this 750 mile transmission line covering approximately 18,000 acres of right-of-way create a greater economic injustice than if FERC promotes and creates incentives for wind farms off the Atlantic coast?  Yes, there could likely be more opposition from more affluent people along the coast of North Carolina or South Carolina, but like the EPA has known, this should not place the residents of Oklahoma or Arkansas at a greater disadvantage with the creation of Plains & Eastern Clean Line.  

Respectfully submitted,
Scott A Thorsen

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