Comments on DEIS - Rockdale-Beltline Option

I previously posted about the Draft Environmental Statement (DEIS) that was recently issued by the Wisconsin Public Service Commission and DNR. (Line Over Monona? and The New Phone Books Are Here!)


You can see the DEIS on the PSC web site. Enter docket number 137-CE-147. Here's the PSC press release: PSC Seeks Public Comment on Draft Environmental Impact Statement for Rockdale to West Middleton Transmission Line.


Having spent a good chunk of last weekend reading the pertinent portions of the DEIS, here are my observations. I expect the City will file comments on the DEIS that may incorporate some of the following remarks. By the way, anyone may file comments and I strongly encourage Monona residents and businesses to do so.


While Monona supports underground (UG) transmission line option if the line goes through Monona my remarks center on the overhead (OH) Beltline route.


Impacts of Rockdale-Beltline.


Figure 2-1C is an aerial view of the Monona segment (Segment H).


Transportation


It is a highly dubious proposition to place a major transmission line in the same corridor as one the state’s busiest highways. Existing right-of-way is already constrained (page 210). That the Beltline will need to be expanded is a certainty, the only question is ‘how soon’. Putting an OH line within the same corridor will increase future highway construction costs, limit future highway expansion options, and possibly require at least partial relocation of the OH line.

The DEIS states that the Stoughton Road / Beltline interchange improvements will be completed before ATC build the OH line. Pages 213-214. Only short term improvements will be completed within the next few years. The major Stoughton Road project is years away.


Aesthetics. Views.

Corrections and amplifications to pages 202 and 220. The DEIS significantly understates the importance of the viewshed looking south from Monona across the wetlands. The DEIS states that the main beneficiaries of the viewshed are drivers on the Beltline. This statement is incorrect. The DEIS further incorrectly assumes that placing the OH line north of the Beltline would reduce the negative aesthetic impact. The viewshed can be enjoyed from numerous points in Monona and that view would be degraded by having a 345 KV line running across it.

Moreover, the viewshed is an important asset for future and existing development in the Broadway corridor. I think the Broadway Corridor Plan refers specifically to the value of this viewshed. I believe this value was also noted during consideration of the Metcalfe development at Hickory Lanes.

Future development. Correction page 214. DEIS incorrectly states that the Monona land use plan show a “continuation of existing uses” along the route. This statement is at best misleading and incomplete. There are development projects on the Broadway corridor that will be significant changes from the current uses, e.g. the Livesey project and the possible Metcalfe-Hickory Lane project.

The OH lines across the wetlands would also negatively impact the aesthetic experience for thousands of boaters and kayakers in the Yahara River / Upper Mud Lake area. Lottes Park is an exceptionally popular boat launch and a source of revenue to the city that could be negatively impacted. There is also a proposed bike path running along the railroad track from Lake Farm Park to McFarland. The OH line would be a significant negative to the aesthetics for the trail user.

Birds. Correction to pages 193-194. I believe there is an eagle’s nest on Belle Isle, which is within 2 miles of the corridor. DNR has imposed conditions on permits for construction of lift stations.

Construction. DEIS notes dangers of damage, possibly permanent, to wetlands as a result of construction. Points the DEIS makes that are worth emphasis: The Monona Wetland Conservancy wetlands are in good condition (page 200). There is a floating mat very close to the construction area. (Page 200). The wetlands become more unstable as one gets closer to the Yahara River (page 201), which makes construction ‘difficult’.

Wetlands and Flooding. Pages 198. Wetlands “attenuate” floodwaters. As FEMA noted in its environmental assessment: "The Belle Isle area of Monona has been flooded an average of once every 4 years for the past 15 years. Recent flooding occurred in 1993, 1996, 1997, 2000, and 2004 during periods of high lake levels due to heavy rainfall." You can add 2008 to that list and make it six times in 16 years.

It is critical that nothing be done to reduce the ability of wetlands to attenuate flooding.

Accessing / Staging construction for three of the towers from the Beltline bridge would decrease safety and increase congestion. The Beltline carries over 110,000 vehicles per day in this area, so that even at night there are always vehicles. There are dollar costs that can be assigned to both increased crashes and travel delay. DOT can provide these to PSC. These dollar costs have not been included in the cost estimates. Pages 200-202. Using a helicopter for construction would be highly diverting for drivers on the Beltline. Page 203.

Spelling. Page 204. Ahuska Park not Ahooska.


Broadway alternate.


Running the transmission line along Broadway is one alternative with negative impacts on residences, WPS, future redevelopment on Bridge Road and Broadway, and the daycare. The Beltline used to run on Broadway (from South Towne Drive to Stoughton Road). When the Beltline was relocated, the city saw that as a major opportunity to improve this corridor. The city has spent the last 20 years working to upgrade and redevelop the Broadway Corridor. Seeing a proposal to put a 345 KV OH line through here after all the investment and effort is extremely frustrating.

Again, I urge people to file comments on this proposal.