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.
Line Energy’s Plains & Eastern project being proposed in conjunction with
FERC in regards to a potential Environmental Impact Study has created some
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?
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.
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
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
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
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.
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.
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.
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.
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.