The Texas Parks and Wildlife Department (TPWD) on Jan. 11 filed with the Public Utility Commission of Texas its comments regarding the Brazos Electric Gyp to AEP Texas Benjamin 138-kV Transmission Line in King and Knox counties in Texas.
As noted in the comments, American Electric Power (NYSE:AEP) and Brazos Electric Power Cooperative are proposing to build the new single-circuit, 138-kV transmission line, which would begin at one of the two proposed locations for the Brazos Electric Gyp switching station along the existing Brazos Electric King to Katz 69-kV transmission line near County Roads 352 and 378 in King County.
The new line would extend northeast until it reaches a location adjacent to the east side of the existing AEP Texas Benjamin substation located west of Benjamin on the north side of U.S. Highway 82 in Knox County, the TPWD said.
The existing AEP Texas Benjamin substation would be expanded to the east to accommodate the new 138-kV transmission line. Depending on the route selected, the total length of the proposed project would be about 19 miles to 25 miles long, the TPWD added.
The project would use either steel or concrete single-pole structures that would vary between 70 feet to 100 feet in height, the TPWD said, noting that the right of way (ROW) width would be 100 feet.
AEP Texas/Brazos Electric retained POWER Engineers (POWER) to prepare an environmental assessment (EA) and an environmental report to support AEP Texas/Brazos Electric’s applications to the commission to amend each of their certificates of convenience and necessity (CCNs) and serves as the ER for the Rural Utilities Service.
POWER evaluated 16 alternative routes and recommended “Route N,” the TPWD added, noting that AEP Texas/Brazos Electric also identified Route N as the route that best addresses certain requirements.
- Is 20.11 miles long, is 0.88 mile longer than the shortest alternative route, and is the fourth shortest route
- Is tied for the third shortest length across bottomland/riparian woodlands (0.42 mile)
- Has the second longest length parallel to other existing ROW (15.04 miles)
- Has the second shortest length across pasture/rangeland (nine miles)
- Has the second least amount of estimated vegetation cleared (81 acres)
- Has the second shortest length across upland woodlands/brushlands (6.44 miles)
- Has the third least stream crossings (26)
The EA did not provide sufficient information based on surveys, remote sensing, modeling, or other available analysis techniques to determine which route would best minimize impacts to important, rare, and protected species. Therefore, the TPWD added, the routing recommendation in its filing is based solely on the natural resource information provided in the CCN application and the EA, as well as publicly available information examined in a Geographic Information System (GIS).
The TPWD said that of the 16 routes evaluated in the EA, Route N appears to best minimize adverse impacts to natural resources, and that it recommends the PUC select a route that would minimize adverse impacts to natural resources, such as Route N.
The TPWD also said that if migratory bird species are found nesting on or adjacent to the project area, then they must be dealt with in a manner consistent with the Migratory Bird Treaty Act, which prohibits taking, attempting to take, capturing, killing, selling/purchasing, possessing, transporting, and importing of migratory birds, their eggs, parts and nests, except when specifically authorized by the Department of Interior.
The TPWD said that it recommends excluding vegetation clearing activities during the general bird nesting season, March through August, to avoid adverse impacts to that group.
Noting that the EA states, “State-listed species such as the Texas horned lizard and Brazos water snake may occur within the study area if suitable habitats are present,” the TPWD said that it recommends avoiding disturbance of the Texas horned lizard, its burrows, and colonies of its primary food source, the harvester ant, during clearing and construction.
Among other things, the TPWD said that the Brazos water snake is generally found in relatively shallow, fast-flowing, rocky areas of the Brazos River and several of its tributaries, as well as along the shores of some reservoirs where suitable habitat is present. The TPWD said that it recommends avoiding the disturbance of rocky stream beds and banks, as well as riparian vegetation.