Statement of Craig Obey, Vice President for Government Affairs, National Parks Conservation Association
Statement of Craig Obey, NPCA Vice President for Government Affairs
Re: "to conduct oversight on the state of the nation’s transmission grid, as well as the implementation of the 2005 Energy Policy Act transmission provisions, including reliability, siting and infrastructure investment"
U.S. Senate Committee on Energy and Natural Resources
July 31, 2008
On behalf of our 340,000 members, the nonprofit National Parks Conservation Association (NPCA) would like to thank you for the opportunity to submit testimony on energy transmission and the implementation of the Energy Policy Act of 2005. Since 1919, NPCA has been the leading voice of the American people in protecting and enhancing our National Park System.
NPCA understands that the Department of Energy (DOE) faces a complex challenge in helping meet our nation’s electricity demands in a deregulated energy environment. Furthermore, we recognize that the addition of new electricity transmission facilities is one of an assortment of actions that can be undertaken to meet our nation’s electricity needs. These facilities, however, should not be developed at the expense of our priceless national heritage.
Simply stated, America’s national parks are not blank spots on a map in which to site new energy infrastructure.
We believe that it would be wrong to site electricity transmission facilities or federal land energy corridors through or adjacent to national parks and that parks should not be included within National Interest Electricity Transmission Corridors (NIETC). Our nation’s citizens take great pride in the remarkable wildlife, scenic beauty, historical character, and inspiring cultural resources found in our national parks. Such sitings would conflict with the laws and policies set in place to protect these national treasures for our children and grandchildren.
Thanks to the foresight of former Congresses and administrations, laws have been established protecting endangered species, historic and cultural resources, and the right of the American public to comment on major government actions affecting our environment.
We feel that the NIETC designations and approval procedures violate several of these laws where the corridors affect national park units. By failing to craft a Programmatic Environmental Impact Statement in the face of a potential significant impact on national parks, the DOE is ignoring the National Environmental Policy Act (NEPA). By failing to take account of the corridors’ impacts upon historic resources, the NIETC designations conflict with Section 106 of the National Historic Preservation Act (NHPA). By failing to undergo consultation with the U.S. Fish and Wildlife Service under the Endangered Species Act (ESA), the DOE is violating Section 7 of this landmark Act designed to protect wildlife. By adversely affecting so many national park resources, the NIETC designations clearly conflict with the National Park Service Organic Act. In addition, by converting the use of lands purchased under the Land and Water Conservation Fund from conservation to energy transmission, the DOE is violating the terms of this federal program. We believe that the DOE must go back to the drawing board to address these shortcomings regarding its NIETC designation.
The treatment of national parks as potential places to site new energy infrastructure goes beyond violating the law; it also constitutes bad policy that will substantially harm the economy of many regions of the country and the very character of many of our national parks.
Already, several private energy utilities, many of which are seeking to use the new NIETC authority, have proposed constructing new electricity corridors that would damage national parks. For example, the New York Regional Interconnect would pass through 73 miles of the Upper Delaware Scenic and Recreational River and impair the very resources the park was established to protect. Additionally, the construction of new electricity corridors within the scenic viewsheds of Gettysburg National Military Park, Antietam National Battlefield, Monocacy National Battlefield, Delaware Water Gap National Recreation Area, Joshua Tree National Park, Shenandoah National Park, Cedar Creek and Belle Grove National Historical Park, the Appalachian National Scenic Trail, and other national parks nationwide could seriously damage park resources, the experience of park visitors, and the tourism-based economies of nearby communities.
NYRI Threatens Upper Delaware Scenic and Recreational River
NPCA is particularly concerned about the New York Regional Interconnect (NYRI) proposal,which would construct a new 400 kV electricity transmission line through the Upper Delaware Scenic and Recreational River. NYRI’s primary route would follow four miles of mountain ridges above the river, while the alternative route would run adjacent along 73 miles of the park’s Wild and Scenic River. Either of these alternatives would impair the Upper Delaware Scenic and Recreational River, a treasure and unit of the National Park System.
The park’s river management plan, developed with the help of 15 communities within the park’s boundary, states that "major electric lines" are an incompatible use anywhere in the river corridor due to their impact on the park’s cultural landscape.1 The management plan also defines a "clear and direct threat" as being an "instance where new land use is proposed which is either: (1) identified on the list of new land uses which are incompatible within the Upper Delaware river corridor; or (2) identified as a land use which would, if developed in such a way, be counter to one or more of the principles and objectives set out in the river management plan and the Land and Water Use Guidelines."2 Clearly, the NYRI, which proposes to erect a 400 kV transmission line through the park, is inconsistent with the park’s river management plan, and qualifies as a "clear and direct threat" to the resources the park was established to preserve.
PPL Electric Utilities and Public Service Enterprise Group Proposal Threatens Delaware Water Gap National Recreation Area
Farther down river is the Delaware Water Gap National Recreation Area, where yet another commercial powerline proposal threatens park scenery and resources. The recreation area is an extremely popular destination for East Coast residents, welcoming 5.2 million visitors in 2006, which makes it the eighth-most visited Park Service site in the National Park System.
PPL Electric Utilities and Public Service Enterprise Group (PSEG) has proposed three electricity transmission alternatives between Berwick, Pennsylvania, and Roseland, New Jersey, that could damage the recreation area. PPL would erect the transmission infrastructure on the Pennsylvania side of the park, with PSEG constructing infrastructure on the New Jersey side.
Two of the three alternatives that PPL is considering would cross the recreation area. "Alternative A" would cross a small section of the park near its northern boundary, while "Alternative B" would cross through the heart of recreation area. Under Alternative B a 500 kV powerline would be added above or beside an already present, though small, innocuous powerline that pre-dates the designation of the recreation area. The path taken by Alternative B would cross:
- at least 15 wetlands;
- 7 areas with known state and federally-listed protected animal and plant species
- 10 Natural Heritage Priority Areas;
- several known pre-historic and historic (National Register-listed or eligible) resources
- 4 heavily used visitor use areas including campsites, a picnic area, and river launch for
- important bald eagle habitat;
- Kittatinny Ridge, a important migratory corridor for raptors;
- the Middle Delaware Wild & Scenic River;
- the Appalachian Trail; and
- 24,000 acres of nearby conservation land managed by the private Blooming Grove Hunting club.
If this alternative were selected, PPL would likely take down the present day 85-foot towers and replace them with gigantic towers up to 250-feet tall. These new towers would rise well above the tree canopy and spoil Delaware Water Gap’s natural and historic landscape. It would also require that the right of way be widened by at least 50 feet. If PPL decided instead to place the new 500 kV line besides the existing small-scale powerline, it would require a significant expansion of the right of way, and still have a major ecological impact and severely compromise the park’s outstanding scenery.
Delaware Water Gap National Recreation Area is already facing major threats from proposals to expand roads, build new bridges, create new right of ways for pipelines, and even a proposal to build a new train line that would traverse the park. Like PPL’s proposal, these are simply inappropriate uses for lands managed by the Park Service, an agency mandated by the Organic Act of 1916 to "conserve the scenery and the natural and historic objects and the wild life therein…"in a manner that will leave them unimpaired for the enjoyment of our children and grandchildren.
Green Path North Proposal Threatens Joshua Tree National Park
NPCA is concerned that Joshua Tree National Park in California could be damaged by a new electricity transmission project, known as the "Green Path North," which has been proposed by the Los Angeles Department of Water and Power (LADWP). Joshua Tree National Park provides a wealth of recreational and educational opportunities for over 1.2 million visitors each year and preserves intact ecosystems of the Mojave and Colorado deserts.
A proposed route for Green Path North would cut a direct line through the only wildlife linkage corridor that connects Joshua Tree National Park with protected lands in the San Bernardino Mountains. Specifically, this route would run just west of the park through the Big Morongo Canyon Preserve, which contains a fragile desert oasis utilized by the park's bighorn sheep and other wildlife.
NPCA is concerned that the construction of the Green Path North Project would fragment sensitive habitat and interfere with the access of sensitive species to water, causing potentially irreparable damage to the park's wildlife. Two other proposed routes would actually cut through Joshua Tree National Park, dramatically expanding an existing power corridor that has been historically and legislatively reserved for electricity from the Hoover Dam. This existing corridor is surrounded by wilderness. NPCA is extremely concerned about impacts to Joshua Tree National Park from multiple proposed routes of Green Path North, and troubled that the park has not yet been contacted to give input to the process, even though two of the proposed routes travel through its land, and one proposed route bisects a crucial wildlife corridor.
Civil War Battlefields and Other National Parks at Risk
The number of electricity transmission lines proposed for construction in the Mid-Atlantic region is staggering. The threat to Civil War battlefields is so immense that last year the Civil War Preservation Trust listed the entire Northern Piedmont, which includes parts of Maryland, Pennsylvania, and Virginia, as one of America’s most endangered battlefields in their "History Under Siege" report.
According to the report: "The Northern Piedmont is home to some of the most iconic battlefields of the entire war. The area is defined by the battles that raged across it, creating a unique cultural identity based on history... In the summer of 2006, electric energy giants Dominion Virginia Power and Allegheny Power announced plans for a 500-kilovolt power line through portions of Maryland, Pennsylvania and Virginia. The proposed routes would devastate environmental, cultural and historical resources throughout the region. The most controversial route, in Northern Virginia, would affect some 48,000 acres of land protected under preservation easements, including 11 existing historic districts, one National Historic Landmark, 19 State and National Historic Sites and seven Civil War battlefields. Other proposals would impact Monocacy and South Mountain in Maryland and Gettysburg in Pennsylvania."3
The Dominion Virginia Power and Allegheny Power proposal calls for erecting electricity towers standing almost 200 feet tall and require up to 200-foot-wide rights-of-way through one of the country’s most historically-rich and protected landscapes. In Virginia alone, approximately 434,000 acres of land visible from the Appalachian National Scenic Trail would be affected. The proposal would also damage the scenic and historical landscapes by passing nearby to Cedar Creek and Belle Grove National Historical Park and Shenandoah National Park, and cross through the Shenandoah Valley Battlefields National Historical District, Rivers of Steel National Historic Area, and the proposed Journey Through Hallowed Ground National Heritage Area.
While siting maps have not yet been released, NPCA is also concerned that a separate 550-mile electricity line proposal by American Electric Power could have serious visual impacts on national parks in Maryland and Pennsylvania. Parks whose scenic viewsheds could be damaged include Antietam National Battlefield, Monocacy National Battlefield, Gettysburg National Military Park, Chesapeake and Ohio Canal National Historical Park. The proposal would also cross through Schuylkill River National Heritage Area, Delaware and Lehigh National Historic Corridor, and the proposed Journey Through Hallowed Ground National Heritage Area.
Designation of Federal Land Energy Corridors Could Degrade Famous Scenery at Arches National Park and Other Western Parks
NPCA also has significant concerns regarding the designation of federal land energy corridors under Section 368 of the Energy Policy Act of 2005. Currently, the Department of Energy and other federal agencies are moving forward with a "West-wide Energy Corridor Programmatic Environmental Impact Statement" for 11 western states. Unfortunately, thus far the agencies have failed to fully comply with the various provisions of the National Environmental Protection Act (NEPA) and other legal requirements that ensure the protection of our national park heritage including the Endangered Species Act and the National Historic Preservation Act. NPCA is very concerned by proposed corridors that would pass adjacent to parklands thereby degrading the iconic scenic views of America’s national parks.
One of the areas of particular concern is Arches National Park where a proposed corridor would pass adjacent to the park’s west boundary degrading the outstanding and famous scenery of the park. Attachment 1 shows how the views from significant portions of the park would be impacted if 150-foot transmission towers were erected every 1,000 feet within the corridor. According to the viewshed analysis, 10 transmission towers would be visible from the visitor center, 34 from the Park Avenue Trailhead, 34 from Double Arch, and 75 from Navajo Arch.
Other parks whose pristine views could be seriously diminished include Mojave National Preserve where two corridors are proposed and Joshua Tree National Park where a proposed corridor on the southern boundary would not only impair the viewshed, but would promote raven roosting and have negative impacts to the federally threatened desert tortoise. Furthermore, many of the proposed energy corridors would intersect and thereby degrade units of the National Trails System.
Marred Viewsheds Are Bad For Business
If electricity transmission lines are inappropriately placed, the tourism-based economies of countless communities could be adversely impacted. In November of 2006, NPCA published an economic study, "The U.S. National Park System: An Economic Asset at Risk," which found that national parks support an astounding $13.3 billion of local private-sector economic activity and 267,000 private-sector jobs, providing a $4 return to state and local economies for every $1 invested in park budgets.
In the Mid-Atlantic region alone, a total of 35 parks (excluding parks located in New York City, Philadelphia, and Washington, D.C.) received over 17.6 million visitors who spend approximately $537.34 million per year, and supported over 13,000 private-sector jobs. In the Southwest National Corridor, 4 national parks received over 10.2 million visits annually, with total visitor spending reaching $303.66 million. This tourism revenue supported over 7,577 jobs.
According to a 2004 study by the University of North Carolina—Asheville Department of Economics, visitation to national parks is affected by the quality of scenic vistas. The study was conducted with the cooperation of the Park Service-managed Blue Ridge Parkway unit, and found that respondents "indicated that the scenic quality along the Parkway is an important reason for their visitation. They indicated they would take fewer trips if scenic quality declines, and would make more trips with scenic quality improvements."4
New electricity transmission lines in Northern Virginia could very well scar the scenic views from Blue Ridge Parkway as it passes through Shenandoah National Park, negatively impacting the tourism-based economies of nearby communities.
The DOE and Congress should not forget the tremendous economic role national parks and open natural areas provide to communities, states, and our country.
NPCA strongly believes that Americans need not be forced to make the false choice between having electricity for their homes and protecting our national heritage. Thankfully, Congress has passed various statutes, including NEPA, to ensure that federal agencies consult the public and work with appropriate stakeholders so that national parks and other protected lands are considered when major federal actions are undertaken.
Certainly, providing adequate supplies of energy at a reasonable cost is an important national priority, but it is not the only national priority. Due to the Park Service’s mandate to "conserve the scenery and the natural and historic objects and the wild life therein…" national parks and other protected lands should be considered off-limits and not included within the geographic boundaries of NIETCs.
Thank you for this opportunity to outline our concerns regarding this important issue. With your help, we can ensure that America’s national parks are protected unimpaired for our children and grandchildren.
1National Park Service. 1986 Upper Delaware River Management Plan. November 1986.
3Civil War Preservation Trust. History Under Siege: A Guide to America’s Most Endangered Civil War Battlefields. 2007.
4University of North Carolina-Asheville. Blue Ridge Parkway Scenic Experience Project Results Synthesis: Phase I Southwest Virginia and Phase II Northern North Carolina. April 2004.