American Electric Power’s (NYSE:AEP) “Cloverdale Extra High Voltage Transmission Improvements Project” should avoid and minimize impacts to undisturbed forest, wetlands and streams, in order to minimize overall impacts to wildlife and natural resources, according to the state Department of Environmental Quality (DEQ).
The DEQ on July 25 provided to the State Corporation Commission (SCC) a summary of potential impacts to natural and cultural resources associated with the proposed project, as well as recommendations for minimizing those impacts.
American Electric Power’s Appalachian Transmission Companies and Appalachian Power Companies have submitted an application to the SCC for a certificate of public convenience and necessity (CPCN) for the construction and operation of the project in Botetourt County, Va.
The project will be built near the existing Cloverdale substation and includes three new 345-kV transmission lines and one new 500-kV transmission line; the partial relocation of an existing 765-kV transmission line, an existing 500-kV transmission line and two existing 138-kV transmission lines; and improvements to the Cloverdale substation, including the construction of a new 500-kV yard to serve as the terminus for the relocated 500-kV line, the DEQ added.
“The DEQ supplement indicates that wetlands and streams will be affected and that the companies have coordinated with state natural resources, historic and transportation agencies,” the DEQ said, adding that about 40 acres of trees will be removed for the proposed project.
Certain permits and approvals that are likely to be necessary as prerequisites to project construction include the Virginia stormwater management program general permit for discharges of stormwater from construction activities.
The DEQ issued several recommendations for consideration by the SCC in its deliberations on the approval and certification of electric transmission facilities and they are in addition to requirements of certain federal, state or local law or regulations.
For instance, the DEQ called for the companies to reduce solid waste at the source, reuse it and recycle it to the maximum extent practicable; to coordinate with the Virginia Outdoors Foundation if the project footprint changes significantly; and to coordinate with the state Department of Historic Resources (DHR) regarding its recommendations to protect historic and archaeological resources.
The DEQ Office of Wetlands and Stream Protection (OWSP) said that according to GAI Consultants, the current proposed transmission lines’ design includes 15 aerial crossings of streams.
The substation is the hub for the regional electric transmission system, the DEQ said, adding that the substation currently is the terminus for two 765-kV lines, one 500-kV line and one 345-kV line, together with several 138-kV lines.
There are limited opportunities to locate and relocate the lines to provide required National Electrical Safety Code (NESC) clearance requirements and the necessary approach angles into the substation bays. The final permitting decision and any further site specific comments regarding avoidance and minimization requirements during the permit process rest with the DEQ Blue Ridge Regional Office (BRRO).
The DEQ further noted that its BRRO recommended that the companies continue to coordinate with the DEQ BRRO Virginia Water Protection (VWP) Program for permitting requirements.
The DEQ Office of Wetlands and Stream Protection (OWSP) recommended that the project maintain 100-foot buffers along either side of streams and place support structure foundations outside of wetlands and streambeds.
Also, no activity may substantially disrupt the movement of aquatic life indigenous to the water body, including those species that normally migrate through the area unless the primary purpose of the activity is to impound water.
Additionally, heavy equipment in temporarily impacted surface waters should be placed on mats, geotextile fabric or other suitable material, to minimize soil disturbance to the maximum extent practicable. Equipment and materials should be removed immediately upon completion of work.
Another recommendation called for herbicides used in or around any surface water to be approved by aquatic use by the U.S. Environmental Protection Agency or the U.S. Fish and Wildlife Service.
On erosion and sediment control annual specifications, stormwater management and local program compliance, the DEQ noted that all regulated land-disturbing activities, including work conducted on companies’ property and all easements owned by another party, must have a project-specific erosion and sediment control plan.
The DEQ also noted that natural heritage resources have not been documented in the project area, adding that the absence of data may indicate that the project area has not been surveyed, rather than confirm that the area lacks natural heritage resources.
The DEQ said that according to the state Department of Conservation and Recreation (DCR), the current activity will not affect any documented state-listed plant and insect species.
To minimize overall impacts to wildlife and natural resources, the state Department of Game and Inland Fisheries (DGIF) recommended that the project avoid and minimize impacts to undisturbed forest, wetlands and streams to the fullest extent practicable; maintain naturally vegetated buffers of at least 100 feet in width around all on-site wetlands and on both sides of all perennial and intermittent streams; and adhere to a time-of-year restriction from March 15 through Aug. 15 of any year for all tree removal and ground clearing activities to protect nesting resident and migratory songbird.
The Virginia Outdoors Foundation, which promotes the preservation of open-space lands, said the planned upgrades will not affect any existing or currently proposed open-space easements. As such, the foundation found no conflict with the project as presented, the DEQ added.
The state Department of Forestry, which was established in 1914 to prevent and suppress forest fires and reforest bare lands, said the project sponsors have been conscientious in avoiding forestland conversion by routing the project through industrial and non-forested areas and making maximum use of existing rights-of-way.
Also, the DHR noted that the new substation, for instance, will not affect significant archaeological resources but additional study may be needed if ground-disturbing activities, such as transmission tower construction, are proposed for any areas beyond the limits of the previous archaeological survey.
The DEQ also said that the state Department of Aviation recommended that the project sponsors ensure that the design of the transmission line and substation prevents interference with pilots’ safe ingress and egress at the airport.
Among other things, the DEQ said that to prevent pollution, the project sponsors should consider contractors’ commitment to the environment when choosing contractors. Specifications regarding raw materials and construction practices can be included in contract documents and request for proposals, the DEQ said.
According to a July 2 hearing examiner’s protective ruling, the SCC has scheduled a public hearing on the project for Oct. 22.