The chosen route for the Susquehanna-Roseland power line project – already approved by state regulators in both New Jersey and Pennsylvania, and already following an existing power line right of way – is the most reasonable path for this critical improvement to the region’s electrical infrastructure, according to formal comments submitted to the National Park Service by Public Service Electric and Gas Company (PSE&G) and PPL Electric Utilities.
The utilities reviewed the routes that would be necessary to connect to alternative routes proposed by the Park Service. Routes other than the one chosen by the utilities would have more impact on people and the environment, and some have “critical flaws” that would make them infeasible to build, according to the utility comments. In addition, choosing a route other than the one already approved by both states would increase costs and cause additional delays that would leave millions of people throughout the region vulnerable to problems with their electricity service.
The two utilities filed their joint comments as part of the Park Service’s Environmental Impact Statement process for the Susquehanna-Roseland line. A permit is needed from the Park Service for the line to cross the Delaware Water Gap National Recreation Area, the Appalachian National Scenic Trail and the Middle Delaware National Scenic and Recreational River.
The utilities also proposed one additional option for consideration: The power line could be constructed entirely within the existing right-of-way already owned by the two utilities in the Delaware Water Gap National Recreation Area, eliminating the need for the park service to grant additional right-of-way.
Currently, the only additional right-of-way needed on any park service lands is an additional 50 ft of right-of-way that PPL has requested on a 0.8-mi segment in the recreation area in Pennsylvania. PPL has determined that it could build the line on a 100-ft path in this segment if necessary. The companies urged the Park Service to evaluate formally this “existing right-of-way” option as one of the alternatives it is studying.
The Susquehanna-Roseland power line is needed to prevent overloads on existing power lines in New Jersey and Pennsylvania, according to the PJM Interconnection, the independent entity responsible for reliability of the electric grid. The PJM requested the line to be completed by 2012, but the utilities said recently that the line won’t be in service until 2014 or later, primarily because of delays in obtaining a permit from the National Park Service.
If the Park Service chooses a route other than the one already approved by state regulators, significant additional delays are expected because of the need to resubmit the new route to regulators in both New Jersey and Pennsylvania. This review process, in addition to time needed for redesign and acquisition of new right of way from private landowners, would add years to the time frame of the project, the utilities said.
Additional delays would have a direct impact on electric customers – both by increasing the likelihood of brownouts or even blackouts during periods of high electricity use, and by resulting in higher costs for the project.
Officials of both utilities commended the National Park Service – and Superintendents John Donahue of the Delaware Water Gap National Recreation Area and Middle Delaware National Scenic and Recreational River, and Pamela Underhill of the Appalachian National Scenic Trail – for the careful NPS study of the issue and for the thorough public comment process, which included three public hearings. The utilities have been cooperating with the park service throughout the process and have met regularly with park service officials to exchange information.
The utilities’ filing included detailed, specific comments on the flaws and impacts of each Park Service alternative route. Many would require much more tree clearing than the route already approved in Pennsylvania and New Jersey and would have additional environmental impacts. Others are drawn by the Park Service on paths where no right-of-way currently exists, or where right-of-way is owned by utilities other than PPL and PSE&G. Some of the routes come closer to population centers, where the overall regional impact would be greater than having the line path go through the recreation area.
The utilities also made the point that the route chosen by the two companies and approved by state regulators crosses the Park Service lands on the path of an existing 230-kV line right-of-way, which existed decades before the Delaware Water Gap National Recreation Area was created and which expressly contains rights to construct additional utility lines.
The existing power line will have to remain in the recreation area, the utilities said, even if the Park Service chooses all but one of the alternative routes, because it is needed for regional reliability. In addition, because of its age, that existing line will have to be rebuilt within 10 years – whether or not the Susquehanna-Roseland line is built along that path.
The utilities concluded that only the chosen route can meet the region’s critical electric needs in a timely way while having the least impact on people, the environment, and on project costs – which are paid by electric customers.
A full copy of the filing has been posted on PSE&G’s project Web site at: pseg.com/reliabilityproject.