Park Service Says No Predetermined Outcome With Transmission Project at Delaware Water Gap National Recreation Area
In a move to counter whispers, National Park Service officials have issued a statement that they have not developed a predetermined position on a power transmission corridor a company wants to run through Delaware Water Gap National Recreation Area, the Appalachian National Scenic Trail, and the Middle Delaware National Scenic and Recreational River.
"It is critically important that the record is set straight on this important issue. Myths and misinformation regarding the NPS environmental analysis of the Susquehanna to Roseland Transmission Line Proposal are very damaging to the public’s ability to analyze the factual information being presented in this extremely important process," Superintendents John J. Donahue and Pamela Underhill said in a joint statement.
At issue is a proposal to upgrade a transmission corridor through the three units of the National Park System. Opponents have said that a transmission-line corridor sprouting 200-foot-tall towers should not be permitted within the National Park System.
In their statement, the superintendents said:
* NPS has neither selected a route, nor directed the utilities (PPL and PSE&G) on which route to build. The NPS is not in the transmission line building business; line construction is the province of the power companies. However, the NPS clearly has the appropriate experience to analyze and determine the potential environmental impacts of any proposal to cross lands and waters of the United States administered by the National Park Service. No possible route can avoid the Appalachian National Scenic Trail, since it runs from Maine to Georgia. The alternatives describe the locations where NPS properties could be crossed, but it remains the responsibility of the power companies to determine where they will site their lines outside of Federal jurisdiction.
* The NPS decision will not be reached until 2012, after the first comprehensive environmental review of this proposal ever conducted is complete, including the analysis of impacts to the human and natural environment and incorporating full public participation. No thorough analysis of this proposed project, including the No Action alternative, has been conducted to date.
* Since all proposed alternatives would cross the Appalachian National Scenic Trail, thus requiring a permit, the NPS is required by law to analyze routes outside of the Delaware Water Gap National Recreation Area.
* The NPS considered, but dismissed, the utilities’ original Routes A and C as potential alternatives. It is the utilities that are proposing to reintroduce their previously dismissed route, not the NPS.
* Trying to place responsibility for their threatened use of their own Route C on the National Park Service by mailing letters to residents, along a route that has already been dismissed by NPS, can only serve to diminish the public trust in this important process.
* PPL targeted its Route C as a future-use right-of-way (ROW) in their official comments submitted to NPS during the February 2010 scoping period. PPL already owns a majority of the rights along this route, according to their application to the Pennsylvania Public Utilities Commission (PUC). The construction of their present preferred alternative does not preclude construction of the future-use ROW, Route C.
* All NPS alternatives were developed using existing ROWs. The proposal by the utilities (Alternative 2) is not the only route sited on existing transmission ROW, as the public has been led to believe. In fact, the proposal by the utilities to the NPS includes a request for the addition of a new permanent, as well as temporary, construction ROW from the NPS.
* Some of the alternatives are significantly shorter in length and could potentially save money for rate payers. For example, Alternative 5 (along Interstate-80) is not proposed to be in the highway corridor, but simply to shadow it, significantly reducing the distance between endpoints.
* Federal Energy Regulatory Commission (FERC) approval for rate increases, allowing for the spread of project construction costs, was received long before the utilities approached the public and NPS about their proposal. NPS did not receive a complete application until March 2009. The duration of the projected schedule for the EIS is well within the normal range for a project of this size and scope and is in fact being completed expeditiously.
* The NPS construction and ROW permits are not the only requirements for building this project. The utilities have not received all of the required permits or approvals from the governmental organizations in New Jersey or Pennsylvania or from any Federal agencies, except for the conditional approvals from Pennsylvania PUC and the NJ Board of Public Utilities.
* PSE&G recently announced a delay of three years before any construction will begin, thus making the in-service date of June 2012 irrelevant. According to PJM Interconnection, they are currently working with the utilities to develop a new plan that will upgrade existing generators to ensure the delivery and distribution of any needed energy and to meet energy demands.
* Similar to the Tocks Island Dam project, a hurried environmental review would only prevent public involvement from taking place, potentially derailing a proposal refined by public input. Repeated environmental disasters have demonstrated the importance of thorough planning and impact analysis before projects are approved.
* The National Park Service does not build transmission lines, but is entrusted with the protection of the scenic, natural, cultural, and recreational resources of these parks now and for future generations. A timely decision will be issued by the NPS once the public has had a reasonable opportunity to review and participate in the process based on a scientific analysis of the impacts to the natural and human environments.