Imagine 190 foot transmission towers through the Delaware Water Gap, between Pennsylvania and New Jersey.

That’s what’s proposed by PSE&G for its Susquehanna-Roseland transmission line.  This quad/tri bundled 500kV line is HUGE, ugly beyond belief, and it’s just so big that I can hardly comprehend, there’s nothing that large that I’ve found.  Others like it are being cancelled by PJM due to lack of demand, and this one should be too…

From the Pocono Record:

Park Service report on power line plan released

Anyway, the National Park Service is doing an Environmental Impact Statement, and leading up to that is “scoping,” which, as Grant Stevenson noted yesterday at the Task Force meeting, is THE most misunderstood term.  I agree.  It just zooms over people’s heads, and comments end up being of the “I hate this project because___” and nothing that relates to what the scope of the environmental review should be.  Utter waste of time, and something to be mindful of with the CapX 2020 transmission scoping meetings coming up.

SCOPE: Range, area of coverage, breadth

So “scoping” in this sense is the range, area of coverage, and breadth of environmental review.

We had comments on the scope a few months ago, and there were something like 6,500 comments.  Yes, that’s right, SIX THOUSAND FIVE HUNDRED!  At the meetings I went to, it was standing room only and the comments were notably on point, they were profound examples of those rare uplifting meetings.  Facilitation of the meetings was so good it felt like they really were interested in what we had to say.  It was all taken down by a court reporter.  THAT level of attention and appreciation is SO rare… and dig this … afterwards I RECEIVED A THANK YOU NOTE FOR PARTICIPATING.  That is a first, I’ve never gotten a thank you note from an agency for showing up and speaking out.  I’m thinking of framing it (after sending it to MN’s Dept. of Commerce).


Here’s their report:

Public Scoping Report – Susquehanna-Roseland transmission

The next step?

The NPS is currently developing preliminary alternatives for the project. Our plan is to host public meetings to present and receive feedback on these preliminary alternatives this summer. Announcements and news releases will be prepared to inform and invite the public to these meetings.

We’ll keep you posted.

It’s out, hot off the press:

BPU Susquehanna-Roseland Order

I feel a Motion for Reconsideration coming on…


Stop the Lines!!!

National Park Service has extended the deadline for EIS Scoping Comments on the Susquehanna-Roseland transmission project.  WHEW!  Now we have until March 12 to send our comments in!

NPS Home Page for Susquehanna-Roseland Transmission Project

Get your clues on Comments from what they do and do not include:

NPS Internal Scoping Document

It’s in the Pocono Times:

Transmission line public scoping period extended

From the NPS blog:

High public interest has prompted the superintendents of Delaware Water Gap National Recreation Area, the Appalachian National Scenic Trail, and the Middle Delaware National Scenic and Recreational River and National Recreation Water Trail to extend by a week the public comment period on a proposal to run a transmission line across the areas.

The comment period was scheduled to end today, but has been extended through March 12.

“Scoping comments,” those that suggest areas the Park Service should examine in preparing an environmental impact statement, are being taken to help agency managers prepare an EIS on a proposal to replace existing 80-foot transmission towers with larger towers (up to 200 feet high) and add an additional 500 kV transmission line.

Park Service officials say the request would necessitate widening the cleared area and the existing right-of-way and constructing access roads. The proposed expanded line and new towers would impact the Delaware Water Gap National Recreation Area; the Middle Delaware National Scenic and Recreational River and National Recreation Water Trail; and the Appalachian National Scenic Trail.

The EIS will analyze a reasonable range of alternatives to meet project objectives; evaluate potential issues and impacts to the resources and values of the Delaware Water Gap National Recreation Area, Middle Delaware National Scenic and Recreational River, and the Appalachian National Scenic Trail park units, and identify mitigation measures to lessen the degree or extent of these impacts.

There are numerous ways for the public to provide comments on the public scoping phase of the planning process, including leaving a message on the Park Planning Information Telephone Line (570-426-2491), submitting comments online through a link on the National Park Service Planning, Environment and Public Comment site, (select Appalachian NST or Delaware Water Gap NRA), or by mailing comments to:

National Park Service
Attention: DEWA PPL EIS Planning Team
Denver Service Center-Planning Division
P.O. Box 25287
Denver, CO 80225-0287

Detailed information about the need for the EIS and the project timeline
can be found on the National Park Service Planning, Environment and Public
Comment site:


The cost apportionment remand at FERC is heating up.   It’s that case where the 7th Circuit threw out the PJM cost apportionment scheme:

Illinois Commerce Commission v. FERC – August 6, 2009

It went back to FERC and so FERC issued an Order requiring PJM to produce things that… well… things that will demonstrate that there’s no need for this project, things that will demonstrate the benefactor of these transmission lines, things that PJM doesn’t really want the world to know, like how they’ve incorporated O-P-T-I-M-I-Z-A-T-I-O-N, things going directly to N-E-E-D!

FERC Order January 21, 2010

Seeing that, well, Stop the Lines had to join in, as did the Municipal Intervenors:

Stop The Lines! Motion for Limited Intervention

PJM begged for more time, an extension of 45 days!

PJM’s Motion for More Time to Answer

And for some bizarre reason, FERC gave it to them:

FERC Order Feb 22 2010

Meanwhile, Exelon wants to bring in the kitchen sink, including 345kV transmission:

Exelon Motion Feb 23 2010

And parties they are a freakin’ and filing:

Baltimore Gas & Electric Response to Exelon

Dayton Power & Light response to Exelon

And then the weirdest of all – the American Wind Energy Ass (AWEA) wants to intervene, citing “the current significance of this issue in the context of efforts to build transmission to bring location-constrained, renewable resources to load…”  Ummmm… SAY WHAT??

AWEA-SEIA Motion to Intervene Out of Time

OK, I give up… in what parallel or alternate universe is the PATH or Susquehanna-Roseland line for wind?  WHERE DO THEY GET THESE IDEAS?  I want to see the basis for that statement.  PRODUCE!

Earth to AWEA — can you spell P-R-O-J-E-C-T M-O-U-N-T-A-I-N-E-E-R?


If you need a hint, go to FERC eLibrary and search for A05-03.  Happy reading!

NPS scoping hearings in progress

February 18th, 2010


Scene from yesterday’s NPS meeting at Camp Jefferson, Lake Hopatcong, NJ

PSEG’s Susquehanna-Roseland transmission line through the Delaware Water Gap is under scrutiny.

Here’s the Daily Record’s photo gallery

Just out – PSEG year end info (just searched SEC and don’t see it there yet):

PSEG 4Q 2009 – Generation Measures

PSEG 4Q 2009 – Electric Revenues

And for some reason, I get that old hook line, a little perverted, i.e., “We gotta lock down our electric revenue, and then we’ll take it higher!”:

Yesterday was the second of three public comment hearings that the National Park Service is holding regarding PSEG’s application to expand the Right of Way and run its Susquehanna-Roseland through the Delaware Water Gap, a premier federally designated “wild and scenic” area.  The good news is that people are really turning out, the first meeting, in Bushkill, PA, was about 100, and this meeting was twice that, standing room only in the log hall of Camp Jefferson.

Here is the NPS’ take on framework and issues for the Environmental Impact Statement:

NPS Internal Scoping Document

Here’s a few snippets that I really find interesting — and of course want to expand on:

Air Quality
Construction and maintenance activities would impact air quality.

The new transmission lines and associated roadways would affect the visual viewshed. Viewshed impacts would be permanent. A separate viewshed analysis should be done for scenic and visual impacts. A comprehensive list of the viewsheds at DEWA does not exist at this time. However, the APPA is considered a scenic viewshed. The baseline conditions are represented by the current viewshed, which has not yet been evaluated.

Climate Change/Greenhouse Gases
How the project contributes to the production of greenhouse gases and climate change, as well as how climate change would impact the project and park resources must be addressed in the EIS.

Viewshed Appreciation
The new transmission lines and associated roadways could adversely affect the visitors’ appreciation of the visual viewshed. These impacts would be permanent. A separate viewshed analysis should be done for scenic and visual impacts for visitor experience.

The one that jumps out to me is “air quality.”  I note that under “Climate Change/Greenhouse Gases” they acknowledge the project contribution of greenhouse gas and climate change, and that also needs to be added to the Air Quality section, the project contribution of pollutants to air quality.

Why?  Check the RTEP, PJM’s 2007 RTEP that this Susquehanna-Roseland project was based on:

Critical RTEP Issues and Upgrades

PJM continues to address a number of issues with
a bearing on reliability in Pennsylvania and the
regional transmission expansion plans required to
maintain it:

• Increasing power transfers through Pennsylvania to feed eastern Mid-Atlantic PJM load centers including those in Pennsylvania are expected to cause overloads beginning in 2016 on key circuits in Pennsylvania. New high voltage backbone facilities are required to mitigate these reliability issues. The new backbone facilities will also be assessed for their ability to support deliveries from a cluster of new coal-fired generating facilities currently proposed for central and northeastern Pennsylvania. Three major new backbone transmission facilities have been approved by the PJM to resolve growing reliability criteria violations in eastern Mid-Atlantic PJM and west/central Pennsylvania, upgrades that are now part of PJM’s RTEP:

• Susquehanna – Lackawanna – Jefferson – Roseland 500 kV circuit
• Amos – Bedington – Kemptown (PATH) 765 & 500 kV circuit
• Mid-Atlantic Power Pathway (MAPP): Possum Point – Calvert Cliffs – Indian River – Salem 500 kV Circuit

2007 RTEP, p.259-260 (emphasis added)

Beginning on p. 262, the RTEP lists 2,712 (check my math) of coal in queue.  Yup, Susquehanna-Roseland could handle that!  Here’s the full PA chapter of the 2007 RTEP — see for yourself:

2007 RTEP – Section 4k – Pennsylvania

The New Jersey one says essentially the same thing:

2007 RTEP – Section 4h – New Jersey

Those new coal plants and the impacts of facilitating/enabling those new coal plants and the impact on the Class I park must be addressed.   The operational impacts, contributions to greenhouse gases, applies equally to air quality.   This was an issue with Voyageurs National Park in the Mesaba Project review, and it should be here.

Here’s the “study area” designated by National Park Service – the “no data” spot is Picatinny Arsenal.  What happens if you build transmission over an arsenal?  What is the impact on the park if Picatinny Arsenal goes BOOM!?!?!


Here are some articles, thanks to Scott Olson ( Fired up and ready to go one more time! ) for compilation: