The following organizations have concerns and/or have provided comments regarding the proposed Mid-Atlantic Power Pathway (MAPP) project. These organizations are not necessarily opposed to MAPP per se, but have concerns regarding the impacts from the right of way and associated facilities for this extra-high voltage transmission line:
The Mid-Atlantic Power Pathway (MAPP) is a 152-mile extra-high voltage transmission line proposed to extend from Possum Point, VA, through Southern Maryland, beneath the Chesapeake Bay and Choptank River, cross the lower Eastern Shore to Southern Delaware.
From MAPP website: www.powerpathway.com
Two massive converter stations-switching yards will also be built as part of the MAPP project. The yellow triangles in the map above mark the location of both facilities. The Chestnut converters northwest of Calvert Cliffs would be housed in buildings up to twice the height of a Walmart and covering ten times the area. The Gateway converter, just east of Vienna, will be just as tall covering half the area.
MAPP is a $1.2 billion project proposed by Pepco Holdings, Inc (PHI) which consists of Baltimore Gas & Electric Company (BGE), Delmarva Power & Light (DPL), and Potomac Electric Power Company (Pepco). PHI claims that MAPP is essential to preventing blackouts, lowering electricity costs, and accessing wind along with other sources of green energy. Our perspective on these issues is presented below.
For additional detail on why PHI believes MAPP is needed and to view detailed maps of the proposed route visit PHI's MAPP website: www.powerpathway.com
First of all, conserve energy through the tips offered by the Maryland Energy Administration.
Second, Sign Our Petition urging Governor O'Malley to shift our reliance from harmful energy sources, like coal, to natural gas, wind, and other cleaner-greener technologies.
Third, let your friends, neighbors, and other acquaintances know about MAPP. In September the Maryland Public Service Commission will hold an evening hearing in: Calvert, Charles, Dorchester, Prince George's, and Wicomico counties. These hearings will be a critical opportunity to voice concerns regarding the MAPP project. We'll post dates, times and locations on our calender as they become available. If you sign our petition and add your e-mail address we'll send you an announcement.
Fourth, consider holding a meeting in your area to help your neighbors understand the pros and cons of MAPP. We'll be delighted to provide a speaker and any other assistance you might need. Contact us at 410-654-3021 or email@example.com.
|Apr 20||Long Term Electricity Report meeting|
|June 3||PSC: Direct testimony due from parties other then applicant|
|July 8||PSC: All rebuttal testimony due|
|Aug||Updated PJM analysis due|
|Aug 5||PSC: All surrebuttal testimony due|
|Sept 6-15||PSC: Evidentiary hearings in Baltimore|
|Sept 19-27||PSC: Evening public meetings in Calvert, Charles, Dorchester, Prince George's and Wicomico counties.|
|Sept-Dec||DOE: Draft EIS released|
|Oct 7||PSC: Initial post-hearing briefs due|
|Oct 28||PSC: Reply briefs due|
|Nov 28||PSC: Proposed order released|
|Dec 16||PSC: Appeal notice/memo issued|
|Jan 4||PSC: Reply appeal memo due|
|Jan 31||PSC: Final order|
|mid-late||DOE: Final EIS released|
|2012-2013||Maryland appellate courts rule on Kemptown substation appeal, possibly defining county vs. PSC authority.|
|DOE||U.S. Department of Energy|
|MDE||Maryland Department of the Environment|
|PSC||Maryland Public Service Commission|
The perception that MAPP is needed stems from the Regional Transmission Expansion Plans (RTEP) issued annually by PJM, the organization which oversees the electricity grid in a 13-state region, including Maryland. PJM identified a dozen "contingencies" which impede the flow of electricity from power plants west of Maryland. Many of these plants burn coal to produce electricity. While coal-fired electricity is the cheapest available to our area, there are many hidden costs as will be seen below. PJMs RTEP alleges that the transmission grid is not capable of delivering power from these plants to Maryland and other Mid-Atlantic states. We use the term "alleged" because this fall the Maryland Public Service Commission (PSC) will determine if the need is genuine and if MAPP can satisfy the need. For further background on the need for MAPP see the CEDS Review of Expert Testimony.
According to the February, 2011 RTEP, there are 13 violations which justify the need for MAPP with regard to reliability. These violations are pictured in RTEP Map 6.3, below.
PJM is scheduled to release an updated analysis in August, 2011. There is a possibility that the new analysis will show that proposed upgrades to the Mount Storm-Doubs transmission line, plus a large new gas-fired power plant at Warrenton, VA, will resolve 12 of the 13 violations. The 13th violation is at the north end of Delmarva where four major transmission lines pass through two substations before carrying electricity onto the Peninsula. The new study may show that there are far less costly alternatives that would resolve this 13th violation as well as MAPP would.
Within the last year or so MAPP proponents have claimed that the transmission line is essential to conveying wind power and other green energy from states to the west and from proposed Atlantic offshore wind farms. This benefit is supported by a study released by the University of Maryland in October, 2010. But later we explain why MAPP may not be needed for this purpose and could, in fact, inhibit green energy expansion.
Since the public first became aware of MAPP in 2008, a number of alternatives have emerged which may maintain reliable, affordable electricity with far fewer adverse effects. Following is a very brief summary of these alternatives. All of these alternatives should be given equal consideration to MAPP and ranked according to the Issues presented in the next section of this website. If such an objective, comprehensive analysis showed MAPP to be the best alternative, then we could begin discussing how to design a least-impact project.
A number of improvements to our existing transmission lines and substations could allow for greater power flows. For instance, "reactive compensation" would resolve the deficiencies which exist in the transmission grid serving Southern Maryland. Reactive compensation changes the natural characteristics of the flow of electricity to make it more compatible with the amount of electric load required at any given moment.
Maryland imports 30% of our electricity. If there were greater generating capacity in the eastern portions of the state, then MAPP would not be needed. For example, 200 to 300 megawatts (MW) of additional generating capacity may resolve congestion on the grid serving the Delmarva Peninsula. A megawatt is the electricity used by 500- to 1,000-homes. A single gas-fired power plant would provide the 200- to 300-MW for Delmarva. The Maryland Offshore Wind Energy Act would make 400 to 600 MW of electricity available to Delmarva residents and others. Perdue is installing 11,000 solar panels at two of its Delmarva facilities. The University of Maryland installed 8,000 panels at their Princess Anne campus.
Since the start of the recession, there have been dramatic decreases in the amount of electricity we'll need in the future. In fact, this was a major factor in the recent cancellation of the PATH transmission line project. Programs like EmPOWER Maryland are furthering declines in electricity use.
If it is determined that a genuine need exists for the MAPP project then consideration should be given to routing the project on existing transmission right-of-way around the head of the Chesapeake Bay (see the pink-purple dashed line in the figure below). PHI claims to have considered this route and found it to be more expensive, with a longer construction time, and causing greater impact. In their amended application to the Maryland Public Service Commission, PHI cited twelve factors which made the northern route inferior. The first factor was: "Permitting and construction concerns with the crossing and placement of structures within the Delaware River and Susquehanna River."
The Northern Route crosses three miles of the Delaware River and about one mile of the Susquehanna, for a total of 4 miles of waterway crossings. Contrast this with the following waterway crossings for the proposed MAPP route (red dashed line above): Potomac River - 2 miles; Patuxent River - 1 mile; Chesapeake Bay - 16 miles; Choptank River - 23 miles, and the Nanticoke River - 1 mile. It is difficult to understand how the 4 miles of Northern Route waterway crossings is more difficult then the 43 miles of waterway crossings for the proposed MAPP route.
Following is a description of the issues of concern to many of the organizations listed above. Again, the alternatives listed above should be thoroughly evaluated with regard to each of the following issues.
MAPP cables would be buried in two trenches beneath 16 miles of the Chesapeake Bay and 23 miles of the Choptank River. First, grapnel anchors would be dragged along both proposed trench locations to remove any large objects buried up to three feet below the Bay and River bottom. Next, a jet plow would be used to excavate two, three- by six-foot trenches in which the transmission cables would be laid. The two trenches would be 80-feet apart. The jet plow would disturb three-feet of bottom sediments on each side of the trenches. Total direct disturbance along the 39-mile route would be 85 acres. A number of highly-sensitive resources are present along this route. Indirect effects could include alteration of the behavior of some fish species by the electromagnetic field (EMF) emitted from the cables. This effect could extend a thousand feet from the cables and extend over 9500 acres of Bay and River bottom.
This would be the first time transmission cables will cross the Chesapeake from shore to shore. In addition to the effect of initial installation, maintenance activities could cause repeated impacts. For example, portions of a similar transmission line - the Cross Sound Cable - had to be reburied several years after initial installation. Also, once the precedent is established by bringing MAPP across the Bay, this will probably become the route of choice for all future utilities which need to cross the Chesapeake. The cumulative effect of multiple utilities could be far greater then MAPP alone.
A coalition of organizations have called upon Governor O'Malley to convene an independent panel of leading Bay scientists to determine if an extra-high voltage transmission line can be safely buried beneath the Chesapeake and, if so, where and how should it be placed. For further detail on this issue visit: ceds.org/choptank.
MAPP is one of several major transmission line projects proposed for the Mid-Atlantic states. The Potomac Appalachian Transmission Highline (PATH) is another. In testimony before the Virginia State Corporation Commission, expert witness Christopher James showed how PATH could increase production at coal-fired power plants to the west and thereby increase emissions of greenhouse gases, respiratory irritants, and other air pollution. The magnitude of emissions increase was on the order of 2% to 6% for the 13-state PJM region. Mr. James cited studies by the Maryland Department of the Environment and the University of Maryland showing that 40% to 80% of Maryland’s air pollution comes from the west with coal-fired power plants serving as a significant contributor. It is claimed that MAPP will make cheaper (coal-fired) electricity available to Maryland. If this is correct then MAPP may have the same effect on coal-fired power plant production and greenhouse gas emissions as PATH. If this is also correct then there could be a significant adverse effect to:
Increased coal-burning also means more coal-mining with all of the attendant environmental impacts: head-of-valley fill, mountain-top removal, sediment pollution, groundwater effects, acid-mine drainage, etc. A recent scientific study summarized the costs of coal as follows:
"Each stage in the life cycle of coal—extraction, transport, processing, and combustion—generates a waste stream and carries multiple hazards for health and the environment. These costs are external to the coal industry and are thus often considered “externalities.” We estimate that the life cycle effects of coal and the waste stream generated are costing the U.S. public a third to over one-half of a trillion dollars annually. Many of these so-called externalities are, moreover, cumulative. Accounting for the damages conservatively doubles to triples the price of electricity from coal per kWh generated, making wind, solar, and other forms of nonfossil fuel power generation, along with investments in efficiency and electricity conservation methods, economically competitive."
In an ideal world Maryland (and all states) would have a plan in which all reasonable options for meeting future energy needs were identified and ranked with regard to the issues listed here. The plan would then set forth specific actions for guiding future energy development to maximize the use of those sources-technologies that provided the best quality of life for Maryland residents.
Unfortunately, Maryland lacks such a plan. Instead we have a first-come, first-approved process. By this we mean that the Maryland Public Service Commission (PSC) is the primary decision-making body with regard to new energy facilities. If the PSC finds that a genuine need exists to improve the reliability, affordability of electric service and a proposed project will satisfy that need, then PSC is pretty much obligated to approve the project. While PSC does have the authority to consider alternatives and impacts in addition to cost-reliability, it is a far cry from a comprehensive energy planning process.
In 2010, many of the concerned groups listed above called upon the Maryland General Assembly to enact a comprehensive energy planning process. This effort failed in part because it was perceived as an indirect attack on MAPP. How ironic that a process which would have shown if MAPP was in our collective best interests was defeated because it might prove the opposite. Fortunately, Governor O'Malley signed an executive order which required the development of a Long-Term Electricity Report; a potentially essential piece of a comprehensive energy plan.
Three converter station-switching yards are proposed as part of the MAPP project: Chestnut - Calvert County, Gateway - Wicomico County, and Mission - Sussex County, DE.
As the name implies, the stations convert AC electricity to DC and vice-versa. The switching yard then allows the electricity to flow to the transmission grid. The stations are needed because the first 63 miles of MAPP (Charles, Prince George's and part of Calvert County) will be 500 kilovolt AC circuits with 83 miles of 640-kilovolt DC circuits. The last six-miles in Delaware will be 230-kilovolt AC circuits.
The converter station buildings are massive. Each will cover 14- to 18-acres and measure 65- to 70-feet in height. To envision just how big the converter will be, consider that a Walmart Supercenter covers 2.5-acres and is about 40 feet high. So you could fit five to seven Walmart Supercenters in a single converter building. The Chestnut facility will have two converter stations. The switching yard is also massive covering 12 to 16 acres. Structures supporting incoming and outgoing transmission circuits are typically 80- to 160-feet tall.
Rezoning: Both the Chestnut and Gateway sites are in areas designated for farm and forest preservation. In fact, large investments have been made in both areas to purchase development rights and take other steps to safeguard rural character. Once in place these large industrial complexes may provide the change in character required to justify rezoning adjoining properties from agricultural to industrial, manufacturing or other intense, incompatible uses.
Stormwater & Recharge: A search of the scientific literature indicates little data is available on the constituents of runoff from converter stations and switching yards. The Maryland Department of the Environment designates a number of similar facilities "stormwater hotspots" due to elevated levels of toxics washed from their rooftops, parking areas and other impervious surfaces. Additionally, the 16- to 52-acres of impervious surfaces would prevent a massive amount of groundwater recharge from occurring. Combined both effects could have a very harmful effect on the sensitive environmental resources associated with the Chestnut and Gateway converter sites.
Viewshed Impact: Visual impacts are a primary concern at both the Chestnut and Gateway converter sites. Both are proposed for rural areas with relatively unspoiled views. It is difficult to envision how the facilities could be screened from view on either site. The Chestnut site adjoins the Star Spangled Banner Byway and is surrounded by numerous sites on the Maryland Historical Trust inventory. The viewshed from the Byway and site is very rural. One sees crop fields, forest, a few homes, barns, and a small country store. The Chestnut converter would dramatically alter the historic integrity of this area.
For further detail on the Chestnut converter contact the American Chestnut Land Trust or Calvert Citizens for Safe Energy. For further detail on the Gateway converter contact the Wicomico Environmental Trust or Friends of the Nanticoke River.
It is generally accepted that Maryland residents do pay more for electricity because of the transmission line congestion impeding cheap coal-fired power from reaching us. An early analysis by PHI indicated that MAPP would save Delmarva households 40¢ to 70¢ per month on an average monthly electricity bill of $81.30. This same analysis indicated Delmarva households would pay an additional 36¢ per month to cover the cost of building MAPP, for a net monthly savings of 4¢ to 34¢ per month. However, Delmarva customers will also pay for the cost of building the PATH, Susquehanna-Roseland, and TrAIL transmission lines. The true net effect is likely an increase in Delmarva electricity bills. Delmarva residents might find the increase acceptable if it avoided blackouts. In the section below on Reliable Electricity you will see this may not be an issue.
Another factor may cause a substantial increase in the cost of MAPP to Maryland residents. Presently, all 51 million residents of the 13-state PJM region pay for all new projects. In other words, we pay for projects in Illinois and Illinois residents will pay for MAPP. This approach of spreading costs over a large area, is called "socialization" has been challenged as unfair to those who never benefit from a project.
In 2009, the 7th Circuit of the U.S. Court of Appeals directed the Federal Energy Regulation Commission (FERC) to look at developing something more reasonable. The issue is this: Why should those who never benefit from a project pay for it? At the other end of the "who pays" extreme is beneficiary pays where those who reap the direct benefits of a project pay for it. In the case of MAPP, Maryland and Delaware residents could be judged to be the beneficiaries. If FERC went with beneficiary pays then any alleged energy cost savings resulting from MAPP would be overwhelmed by the hike in our electric bills to pay for this $1.2 billion project. FERC (and the Court) have yet to reach a decision on who pays.
The Emory Grove Station is proposed for a site near Reisterstown, in Baltimore County, MD. The applicant's assessment of the Northern Alternative cited this substation as a component. However, BGE claims the Emory Grove Substation has nothing to do with MAPP. This facility is included here to illustrate the need to carefully examine alternatives to MAPP, like the Northern route. The substation is proposed for a site within the Piney Run Rural Legacy Area. It would cover an area of 30- to 40-acres with many of the same impacts as the converter stations addressed earlier. The Chestnut converter abuts another Rural Legacy Area known as Calvert Creeks. There are 33 Rural Legacy Areas which encompass 849,449 acres or 11% of Maryland. These areas contain some of our most productive and vulnerable farm and forestlands. But only 8% of these lands are actually protected from incompatible uses, such as the Emory Grove Substation. A recent CEDS study showed that most Maryland counties lack effective measures for preserving Rural Legacy Areas from incompatible uses, such as substations (and converter stations). For further detail contact the Valleys Planning Council.
The original MAPP route would have clear-cut a swath through some of the most productive farms and commercial forests on Maryland's Eastern Shore. A tremendous public and private investment has made in preserving these farms and forests through the purchase of development rights and other mechanisms. Though the current route impacts less farm and forestland, negative effects remain. Here are a couple of examples:
The proposal to bring MAPP up the Choptank River reduces the number of farms and forests impacted. But if the independent review called for above shows that the Choptank route is far too harmful, then PHI may seek to run MAPP through the original route.
Both the Chestnut and Gateway converter stations-switching yards are proposed for areas designated for farm and forest preservation. Both facilities would jeopardize preservation efforts by turning agricultural areas into industrial. This change could then be used to justify rezoning adjoining lands for other industrial or commercial uses.
There are nearly a hundred cultural resources within a half-mile of the proposed MAPP route. The project could negatively affect these resources through direct disturbance or by altering the historic integrity of the area in which each is located.
For instance, the original route would have brought an overhead transmission line through areas critical to the proposed Harriet Tubman Underground Railroad Park and Byway. Within much of the park and byway areas, visitors can see cropfields and wooded swamps much as they appeared in Harriet Tubman’s time. Locating an overhead transmission line and associated structures in this area would detract greatly from the ability of visitors to understand the many difficulties Ms. Tubman and other conductors faced as they fled across cropfields at night and hid in swamps during the day. Should burying the transmission lines beneath the Choptank River prove too harmful, the applicants may seek to bring MAPP back to the original route.
The Chestnut converter would be located next to the Star Spangled Banner Byway. The sites is surrounded by numerous resources on the Maryland Historical Trust inventory. The 70-foot tall by thousand-foot long converter buildings, plus the 80- to 160-foot tall towers, would be clearly visible from the Byway and many of the inventory sites. For further detail on the Chestnut converter contact the American Chestnut Land Trust or Calvert Citizens for Safe Energy.
MAPP could affect human health in two principal ways: air pollution and electromagnetic fields (EMF).
Air Pollution: The earlier section on Coal Pollution, explained that a substantial portion of the pollution affecting Maryland air quality originates at coal-fired power plants to the west. If MAPP increases production at these plants then Maryland air quality could decline. In Coal’s Assault on Human Health, Physicians for Social Responsibility stated:
"Coal combustion in particular contributes to diseases affecting large portions of the U.S. population, including asthma, lung cancer, heart disease, and stroke, compounding the major public health challenges of our time. It interferes with lung development, increases the risk of heart attacks, and compromises intellectual capacity."
Electromagnetic Fields (EMF): There is a growing consensus that the electromagnetic field (EMF) emitted by transmission lines pose a genuine health threat. For example, in 2006 the State of Maryland concluded: "Studies have consistently shown increased risk for childhood leukemia associated with ELF magnetic fields..." A 2005 British study showed that one out of every hundred or so cases of childhood leukemia occurring within 2,000 feet of high-voltage (≥132 kilovolt) transmission lines was due to EMF from the line.
About 80% of the 500-kilovolt MAPP project will consist of adding conductors (cables) to existing transmission line corridors. Analyses conducted by the applicants consultants show that in some locations this will double the EMF from the corridor. Increases in EMF could also occur along other lines which carry more power due to MAPP.
The applicants claim that the project will create 717 jobs during the peak year of the five years required to construct MAPP. The applicants also claim that during this five-year period MAPP will add $209 million to the local economies of the six counties the project passes through: Calvert, Charles, Dorchester, Prince George's, Sussex, and Wicomico.
There are other jobs which may be lost as a result of MAPP. Consider Dorchester County where farms, commercial forests, commercial fishing, and tourism are all major components of the local economy. Major existing tourist attractions in Dorchester County include Blackwater National Wildlife Refuge which alone adds nearly $28 million annually to the local economy. Proposed Harriet Tubman Underground Railroad facilities could add another $9 to $21 million a year. Tourism job multipliers typically range between 25-30 per million dollars in sales. So just the Blackwater and Harriet Tubman facilities would support 925 to 1,470 permanent jobs vs. the 717 temporary jobs of MAPP. Should MAPP return to the original route near Blackwater and Harriet Tubman heritage areas a portion of the tourism income and jobs could be lost. This simplistic analysis illustrates how important it is to consider both sides of the jobs equation.
Mattawoman Creek is one of the highest-quality waterways in Southern Maryland. Mattawoman is noted for an abundance of fish, wildlife, and an unusually large number of threatened-endangered species. About 24 miles of MAPP passes through the Mattawoman Creek watershed (see area bounded by the green line below). The project consists of adding a second 500-kilovolt circuit to existing transmission line support structures. But this would also require clearing 50- to 100-feet of forest along one side of the transmission right-of-way. This will result in the loss of 175 acres of Mattawoman Creek forest and 76 acres of wetlands would be permanently impacted.
To put this in perspective consider that the largest wetland impact caused by a single project since at least 1991 was 34 acres. In other words, MAPP impacts within the Mattawoman watershed would be twice as great as the next largest wetland impact on record. A typical development project causes a net forest loss of 2.8-acres. The forest loss caused by this portion of MAPP would equal 27 typical development projects.
The harm caused by these impacts is compounded by the extent of development within the Mattawoman watershed. A large body of scientific evidence shows that stream health declines when 8% to 10% of a watershed is covered by buildings, streets, parking lots, and other impervious surfaces. Other studies show that forest is essential to countering the effects of impervious surfaces. A healthy stream can exist if a minimum of 50% of a watershed is covered with forest and impervious area does not exceed 10%.
The Mattawoman Creek watershed is about to pass to the wrong side of both thresholds. The loss of 175 acres of forest, including 76 acres of extremely valuable forested wetlands, could push the Mattawoman over a brink where it is no longer suited for human uses and highly-sensitive aquatic communities. Alternatives to resolve these impacts were offered in comments on the wetland permit applications being considered by the Maryland Department of the Environment and the U.S. Army corps of Engineers. For further detail contact the Mattawoman Watershed Society.
The MAPP transmission line is proposed to cross over the Nanticoke River just upstream of the Route 50 bridge. The Nanticoke River is one of the most pristine and biologically diverse of the Chesapeake Bay tributaries; it is free of dams and supports robust fisheries. The Nanticoke watershed provides habitat for many threatened plants and animals. It has the northernmost stands of bald cypress on the Atlantic Coast and the highest concentration of bald eagles in the northeastern United States. It is a strategic target for land preservation by both private and governmental interests. The river shore has properties on the National Register of Historic Places, and the Nanticoke is a major component of the Captain John Smith National Historic Water Trail.
The transmission line crossing would be made with the cables supported on 90-foot towers. Presently the viewshed to the north of the Route 50/Nanticoke crossing is that of a wide river meandering past extensive wetlands and a few farms. The overhead cables would despoil this view. This would be true for where the transmission lines cross the River and for the area several miles to the east and west of the Nanticoke where the lines would still be visible.
If the independent review recommended above under the Chesapeake Bay & Choptank River heading shows that the cables can be submerged without undue impact and other possible River impacts are resolved, then consideration should be given to placing the transmission line underground and submerged from the Choptank River to a point east of the Nanticoke outside the river viewshed.
The Gateway converter and switching yard is proposed for a site one mile east of the Nanticoke. The facility would likely be visible from the eastern approach to the Route 50 bridge over the Nanticoke. Another concern is how little is known about the quality of stormwater runoff from a converter station and switching yard. A number of toxic pollutants could be present. If this is correct then the most effective pollutant removal practices might not be permitted. Instead these pollutants would wash into Nanticoke tributary streams.
A transmission line presently passes over the Patuxent River from the Chalk Point substation to the Calvert County shore. New support structures would be placed in the river to carry the MAPP transmission line over the Patuxent. As with the Nanticoke, if the review by an independent panel of leading Bay scientists shows a transmission line can be safely submerged, then this option should be considered for the Patuxent. For further detail contact the Patuxent Riverkeeper.
A transmission line presently crosses the Potomac River from Possum Point, VA to Moss Point in Charles County. The crossing is 30 miles downriver of Washington, D.C.
As with the Patuxent, new support structures will be constructed across the Potomac to carry the MAPP transmission line. The left photo above shows the crossing presently appears. That on the right is how the Potomac River would appear with the MAPP structures. Consideration should be given to placing both the existing transmission line and MAPP beneath the Potomac, provided Bay scientists find this can be safely done.
There have been a number of studies regarding the effect of transmission lines on property value. Taken as a whole, these studies show varying effects in terms of dollar amount, distance and duration. The following studies show a 4% to 25% decline in the value of properties located 1,000-feet or more from a transmission line.
Among the most frequently asked questions about MAPP is whether the project is the best option for maintaining reliable electric service. Usually the questions focus on two areas: Southern Maryland and the Delmarva Peninsula. Following is a summary of the answers provided by various experts
Is there a need for MAPP with regard to the reliability or cost of electric service in Southern Maryland (West of the Chesapeake)? MAPP is not needed to maintain the reliability of Southern Maryland electric service. Reactive compensation would resolve the deficiencies which may exist in the transmission grid serving Southern Maryland. Reactive compensation changes the natural characteristics of the flow of electricity to make it more compatible with the amount of electric load required at any given moment.
Is there a need for MAPP with regard to the reliability-cost of electric service on the Delmarva Peninsula? There are no major local problems on Delmarva which would require MAPP. Voltage collapse claimed by PJM, if it occurred, would likely black out Delmarva. However, there are other options for resolving deficiencies in the transmission grid serving the Delmarva Peninsula which would be far less expensive (and could be more quickly implemented) then MAPP. First of all, the general slow down in the growth in electricity usage has probably postponed the date when corrections will be needed for the grid feeding into the Delmarva Peninsula. Expanding electric generating capacity on Delmarva or in New Jersey would be a better solution than MAPP. As little as 200- to 300-megawatts of additional generating capacity could solve the problem. This could come from a single new gas-fired power plant or from the wind farms proposed off the Delmarva coast. More reactive compensation would also help.
Long Distance Transmission May Reduce Reliability: Most of the major blackouts which have occurred in the United States were in areas served by long transmission lines carrying electricity from remote generating facilities. MAPP would be conveying electricity from the Ohio Valley and other remote locations. The cheaper electricity made available via MAPP would reduce the likelihood that new generating facilities would be built locally. The net effect could be an electricity transmission more brittle and subject to interruptions then what we have today.
The counties in which MAPP will be located may receive $1- to $3-million per year in property tax revenue. While this is certainly a substantial benefit it may not compensate for revenue losses attributable to MAPP. Areas of loss addressed elsewhere in this website include: coal pollution, farm and commercial forests, commercial and recreational fishing, human health, jobs, and property value.
MAPP transmission line support structures will range from 125- to 195-feet high and the converter station buildings would be up to 70 feet tall. To put these heights in perspective consider that a typical Walmart building is about 40-feet high. Both the buildings and support structures could be visible from considerable distances. Both the Chestnut and Gateway converters are proposed for areas where views are presently of a very rural landscape. At least a hundred sites on the Maryland Historical Trust inventory are located along the proposed MAPP route. The transmission line and converters would impart an industrial appearance to the rural settings of many of these sites.
It has been claimed that MAPP is essential to tapping wind power off the Atlantic coast. While one could argue that MAPP can only help, as we've seen MAPP could come with a very large price tag. The key question is: Are the benefits of MAPP worth the price? In the case of wind power the answer appears to be no. Here's why.
The Delmarva transmission grid has sufficient capacity to convey the electricity generated by offshore wind farms off the Peninsula to other points in the USA. The flows on the Delmarva grid are congested with regard to getting electricity from outside the Peninsula to points on the Peninsula. In other words, the grid is congested for electricity flows from north to south but not on the Peninsula. No congestion exists with regard to electricity flows from south to north on the Peninsula.
Offshore wind farms would be sending electricity from south to north. It appears that the existing Delmarva transmission grid could accommodate perhaps 1,600- to 3,000 megawatts (MW) or more of electricity flow from south to north. The Maryland offshore wind initiative is calling for 400- to 600-MW. In other words, Delmarva transmission capacity may exceed the amount of proposed wind energy.
Furthermore, with an additional 200- to 300-MW of electricity generating capacity on the Peninsula, the Delmarva north-to-south flows would be reduced even further and the supposed voltage collapse on the grid feeding into Delmarva from the north would be mitigated. The congestion issue would be resolved. This electricity could come from offshore wind or any of several new generating sources under consideration for the Peninsula.
Following is a summary of the major categories of permits and other approvals the applicants must obtain to begin construction of the MAPP transmission line.
There are a number of local permits-approvals which MAPP will require from five Maryland counties: Calvert, Charles, Dorchester, Prince George's and Wicomico. These permits-approvals could include: building permit, grading permit, erosion and sediment control plan approval, Environmental Site Design approval, stream-wetland buffer waivers-variances, special exception or conditional use permit, access across County right-of-ways, and forest conservation plan approval. Of these the special exception-conditional use permit likely provides counties with the greatest ability to ensure that the MAPP project causes the least negative impact. However, CEDS recently completed a review of most Maryland county zoning laws and found that few contain adequate safeguards.
It is generally believed that Maryland Public Service Commission (PSC) authority preempts County authority. This is almost certainly true when it comes to overhead transmission lines. It is less clear with regard to converter stations, switching yards and substations. In fact, stand-alone substations have traditionally required only local approval and none from PSC. In 2010, Frederick County denied a special exception for the Kemptown Substation. The applicants have appealed this decision. It is anticipated that the Maryland appellate courts will decide this case sometime in 2012 or 2013. This decision should establish where County and PSC authority begins and ends.
The applicants requested a low-interest loan from the federal government for the portion of MAPP known as Phase II. This portion extends from Chalk Point to the Indian River substation in Delaware. Because of the proposed use of HVDC and other innovative technology, this portion of MAPP qualifies for the loan program.
The loan has triggered the need for an Environmental Impact Statement (EIS). In March, the U.S. Department of Energy (DOE) held Scoping Meetings in Calvert, Dorchester, and Sussex counties. The Draft EIS should be released for public comment sometime between September and December, 2011. The Final EIS would then be released in mid- to late-2012. Construction of Phase II of MAPP cannot begin until approved in the Final EIS.
While the Scoping comment period ended April 4, 2011, DOE will continue accepting comments, which should be directed to:
Office of NEPA Policy and Compliance (GC–54)
U.S. Department of Energy
1000 Independence Avenue, SW.,
Washington, DC 20585
Be certain to reference DOE/EIS-0465 in your comments.
Following are links to some of the many excellent comments submitted to DOE during the Scoping meetings:
The applicants must obtain a Certificate of Public Convenience and Necessity (CPCN) from the Maryland Public Service Commission (PSC). In 1972, the PSC issued a CPCN in Case No. 6562 for the first 52 miles of MAPP which involves stringing a second 500-kilovolt AC circuit along an existing transmission line corridor in Charles and Prince George's County. In Case No. 9179, PSC is considering a CPCN for the overall need for MAPP, including the first 52-miles, and the siting of Phase II (Chalk Point to the MD/DE line).
To fully participate in the PSC proceedings, one must become an intervener. This involves a petition to the PSC Hearing Examiner. Those who own property next to the proposed route do not need to be represented by a lawyer. All others do. One can also become an "interested party" by sending a written request to the PSC Hearing Examiner. Interveners can pose questions to the applicants. These questions are called "data requests" and the applicant is required to respond within ten business days. Interveners can also participate in the evidentiary hearings set to begin in September (see Calendar above).
Most of the important documents in the case are posted on the PSC website: psc.state.md.us When you reach the main PSC webpage enter 9179 in the Case Search block, click Go, and a page will appear with more then a hundred documents in Word or Adobe pdf format.
The only documents not posted on the PSC website are responses to the data requests. For your convenience the applicant's responses to data requests are posted below:
To participate effectively in the PSC evidentiary hearings one really need an attorney and expert witnesses. Needless to say, this is an expensive undertaking. To get a sense of the level of expertise the PSC proceedings entail, download the CEDS summary of MAPP expert witness testimony from December, 2009.
From September 19-22 and then September 26-27, PSC will hold evening public hearings in each of the five counties affected by MAPP: Calvert, Charles, Dorchester, Prince George's and Wicomico. This is the best opportunity for us non-interveners to make the PSC Hearing Examiner aware of our concerns. By August, PSC should have finalized the date, time and location of each hearing. Of course we'll post that information on this website as soon as it becomes available on our calendar. If you sign our petition and give us your e-mail address we'll send you a notice.
The applicants must obtain wetland permits and other approval from the following agencies:
At this time the applicant has only requested wetland permits for the first 52 miles of MAPP; the Charles and Prince George's County portion. MDE held a public information hearing regarding this application on January 24, 2011. The comment period was extended to March 1, 2011.
On March 4th, MDE sent the following letter to Pepco setting forth additional information required to continue the application review:
On September 9, 2011, the MDE sent a letter to Potomac Electric Power Company (PEPCO) stating that approval was granted to impact 118 acres of forested nontidal wetlands. Of course the impacts would result from building the portion of MAPP from Possum Point, on the Potomac River shore in Charles County, to Chalk Point on the Patuxent River. The letter is posted at: http://ceds.org/MAPP/MDE_Wetland_Letter_9-9-11.pdf. The approval letter did contain three conditions, the most significant of which may be final approval of Forest Harvest Plans by Charles County. It is still possible that Charles County aquatic resource advocates could succeed in convincing County officials to reduce impacts to Mattawoman Creek and other highly valued waters through the Forest Harvest Plan.
The impact of this first 52 miles of MAPP is astounding, particularly given that it takes place in an existing transmission line right-of-way. MAPP will be created by adding a second 500-kilovolt AC circuit to existing support structures. However, this will require clear-cutting forest along 50- to 100-feet of the right-of-way. This will result in the loss of 344 acres of forest and 118 acres of wetlands would be permanently impacted. To put this in perspective consider that the largest wetland impact caused by a single project since at least 1991 was 34 acres. In other words, MAPP impacts would be 3.5-times greater then the next largest wetland impact on record. A typical 20-acre development project causes a net forest loss of 2.8-acres. The forest loss caused by this portion of MAPP would equal 123 typical development projects. Several of the following comments offer alternatives that would greatly reduce - possibly eliminate - these impacts.
Two government agencies submitted comments to MDE:
Detailed comments were submitted by:
In addition, 40 individuals and 7 organizations submitted comments expressing concern about MAPP wetland impacts:
Finally, MDE received comments from 7 groups supportive of the MAPP project:
Following are websites maintained by groups concerned about other transmission line projects:
Following is a summary of events which have transpired since citizens first learned of the MAPP project.
On August 8th PJM staff recommended a halt to both the MAPP and PATH transmission line projects. This action resulted from modeling that showed neither project was needed to maintain the reliability of electric service for at least the next 15 years. A combination of declining energy use and new generating facilities have resolved issues that once threatened reliability. PJM is scheduled to act on the staff recommendation on August 24th.
When both projects first emerged numerous individuals and citizen groups began raising questions about need and alternatives that might satisfy that need without such sweeping impacts to homes, farms, the environment, electricity prices, and other factors. This prompted elected officials to pose these same questions. This in turn slowed down the permitting process while essential studies were initiated. Had citizens not acted then these multi-billion dollars transmission lines could have been in the midst of construction by the time we learned that neither was needed.
A truly comprehensive energy planning process is urgently needed to prevent such unwarranted, ultra-expensive projects from taking our energy future in the wrong direction. We sincerely hope the MAPP and PATH near-disasters serve as a wake-up call.
Community & Environmental Defense Services (CEDS) serves as facilitator for this effort. If you have any questions or suggestions then please contact:
Community & Environmental Defense Services
21300 Heathcote Road
Freeland, Maryland 21053