ift^ -1 ;- V -''- -i.'-'tkol CEHTER August 3, 2015

Transcription

1 Molly Joseph Wrd Sectetryof Nturl Resources ift^ L -1 ;- V -''- -i.'-'tkol CEHTER COMMONWEALTH ofvirghmut -5 A!3 : 52 DEPARTMENT OF ENVIRONMENTAL QUALITY Street ddress: 629 EstMin Street. Richmond, Virgini MiUng ddress: P.O. Box 1105, Richmond. Virgmi Fx: TDD (804) Dvid K. Pylor Diiector ( S«) I S2 m K3 August 3, 2015 Mr. Joel H. Peck, Clerk Document Control Center Stte Corportion Commission 1300 E. Min Street, Tyler Bldg., 1 s t Floor Richmond, Virgini RE: Appliction of Virgini Electric nd Power Compny (Dominion) for Certificte of Public Convenience nd Necessity: Yrdley Ridge 230kV Double Circuit Trnsmission Line Loop nd 230 kv Yrdley Ridge Switching Sttion, Cse No. PUE (reviewed under DEQ # ). Der Mr. Peck: As requested in Ms. Ashley Mcko's My 27, 2015, letter (received June 1, 2015), the Deprtment of Environmentl Qulity (DEQ) hs coordinted the review of the bovereferenced ppliction, focusing on the DEQ supplement included with the ppliction. The purpose of the review is to develop informtion for Stte Corportion Commission (SCC) stff bout potentil impcts to nturl nd culturl resources ssocited with the proposed project. Bsed on comments submitted by reviewers, we re providing summry of potentil impcts to these resources from construction nd opertion of the substtion nd electric trnsmission lines, s well s recommendtions for minimizing those impcts nd for complince with pplicble legl requirements. This report includes copies of the comments submitted by reviewers. Thnk you for the opportunity to review the ppliction for SCC certifiction. We trust tht you will find our report helpful in your review process. If you hve ny questions, plese feel free to cll me t (804) or Jnine Howrd t (804) Bettin Sullivn, Progrm Mnger Environmentl Impct Review

2 Joel H. Peck DEQ # PUE Pge 2 ec: Ashley Mcko, SCC M Chrlotte McAfee, Dominion O Robbie Rhur, DCR ^ Amy Ewing, DGIF Roger Kirchen, DHR Greg Evns, DOF Cin Dbestni, VDOT NoVA Susn Simmers, DOAv Keith Tignor, VDACS Roy Soto, VDH Tony Wtkinson, VMRC Mrth Little, VOF G. Mrk Gibb, Northern Virgini PDC Tim Hemstreet, Loudoun County p ^ ^ p

3 COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Slreer ddress: 629 EstMin Street, Richmond, Virgini Molly Joseph Wrd Miling ddress: P.O. Box 1105, Richmond. Virgmi cuvid K. Pylor SeciemryofNmurl Resources Fx: TDD (804) 698^021 Director (8M) p M COMMENTS OF THE DEPARTMENT OF ENVIRONMENTAL QUALITY Concerning the Appliction of Virgini Electric nd Power Compny (Dominion) for Certificte of Public Convenience nd Necessity: Yrdley Ridge 230kV Double Circuit Trnsmission Line Loop nd 230 kv Yrdley Ridge Switching Sttion, Cse No. PUE (reviewed under DEQ # ). The following comments re intended to provide technicl ssistnce to the Stte Corportion Commission (SCC) in evluting the project. The following gencies nd commission joined in this review: Deprtment of Environmentl Qulity (DEQ) Deprtment of Consen/tion nd Recretion (DCR) Deprtment of Gme nd Inlnd Fisheries (DGIF) Deprtment of Historic Resources (DHR) Deprtment of Forestry (DOF) Deprtment of Trnsporttion (VDOT) Deprtment of Avition (DOAv) Virgini Outdoors Foundtion (VOF) Loudoun County The Deprtment of Agriculture nd Consumer Services, Deprtment of Helth, Mrine Resources Commission, nd the Northern Virgini Plnning District Commission lso were invited to comment. The informtion considered in this review includes Dominion's Appliction for Approvl nd Certifiction of Electric Fcilities, Yrdley Ridge 230 kv Double Circuit Trnsmission Line Loup nd 230 kv Yrdley Ridge Switching Sttion, Cse No. PUE , focusing on the informtion in the DEQ supplement.

4 Joel H. Peck DEQ # PUE PROJECT DESCRIPTION yj m Dominion hs submitted n ppliction to the Stte Corportion Commission (SCC) for Certificte of Public Convenience nd Necessity to construct new 230 kv Yrdley Ridge Switching Sttion djcent to the proposed Northern Virgini Electric Coopertive (NOVEC) Yrdley Ridge Delivery Point nd overhed 230 kv double circuit trnsmission line in Loudoun County, Virgini. The SCC sked DEQ to conduct coordinted review of the environmentl report (DEQ Supplement) ssocited with the ppliction. The Yrdley Ridge Loop nd Switching Sttion (the "project") re plnned in order to provide requested trnsmission service to NOVEC, to mintin relible service forthe growth in Loudoun County, nd to comply with mndtory North Americn Electric Relibility Corportion (NERC) Relibility Stndrds by incresing trnsmission cpcity. There is one proposed route nd one ltemtive route for the trnsmission line loop. The length of the proposed route is 0.4 mile nd commences t tp point long the Brmbleton-BECO Line #2137 trnsmission line, pproximtely 150 feet west of the plnned Loudoun County Prkwy extension. The lternte route is 0.7 miles in length nd commences t more western tp point long the Brmbleton-BECO Line #2137 trnsmission line, pproximtely 740 feet north of the intersection of Trde West Drive nd Weekly Court. The proposed nd lternte routes would require new 100-foot right-of-wy, nd new electric trnsmission esements re needed for the entire length of both routes. LIST OF PERMITS OR APPROVALS The following permits nd pprovls re likely to be necessry s prerequisites to project construction. The detils of these requirements pper in the "Regultory nd Coordintion Needs" section of these comments. 1. Wter Permits (see "Regultory nd Coordintion Needs", Item 1, pge 25).. Section 404 permit (e.g. Ntionwide Permit 12, if pproprite). Required pursunt to the federl Clen Wter Act nd issued by the U.S. Army Corps of Engineers for impcts to jurisdictionl wetlnds nd/or wters of the United Sttes. b. Virgini Wter Protection Permit (9VAC etseq.). Issued by the Deprtment of Environmentl Qulity (DEQ) for impcts to wters nd jurisdictionl wetlnds, including isolted wetlnds.

5 Joel H. Peck DEQ # PUE Subqueous Lnds Mngement (see "Regultory nd Coordintion Needs", Item 2, pge 25). Subqueous Lnds Permit pursunt to Section of the Code of Virgini. Issued by the Virgini Mrine Resources Commission for encrochments in, on or over stte-owned subqueous beds. yn 3. Erosion nd Sediment Control nd Stormwter Mngement Plns (see "Regultory nd Coordintion Needs," Item 3, pge 25).. Generl erosion nd sediment control specifictions pursunt to Virgini Code :55. Generl erosion nd sediment control specifictions re subject to nnul pprovl by DEQ. b. Erosion nd Sediment Control Plns for construction of fcilities not covered under Virgini Code :55 re subject to pprovl by the pproprite pln pproving uthority. 4. Stormwter Mngement Progrm Permit (see "Regultory nd Coordintion Needs," Item 4, pge 25). Generl Virgini Pollutnt Dischrge Elimintion System (VPDES) Permit for Dischrges of Stormwter from Construction Activities (VAR10) (9VAC etseq.) involving lnd disturbnce of 1 cre or more. Coverge under this generl permit is pproved by DEQ. 5. Air Qulity Permits or Approvls (see "Regultory nd Coordintion Needs," Item 5, pge 26).. Open Burning Permit (9VAC5-130 etseq.). For open burning involving demolition debris. b. Fugitive dust emissions (9VAC etseq.). Governs btement of visible emissions. c. Asphlt pving opertions (9 VAC etseq.). Sets out limittions nd time-of-yer restrictions on the use of "cut-bck" sphlt. d. Fuel-burning equipment (9VAC5-80, Article 6, Permits for New nd Modified Sources). Governs the instlltion of fuel-burning equipment (boilers, genertors, compressors, etc.) or ny other ir pollution emitting equipment. 6. Solid nd Hzrdous Wste Mngement (see "Regultory nd Coordintion Needs," Item 6, pge 26).. Applicble stte lws nd regultions include: Virgini Wste Mngement Act (Code of Virgini Section et seq.); Virgini Hzrdous Wste Mngement Regultions (VHWMR) (9VAC20-60);

6 Joel H. Peck DEQ # PUE p Virgini Solid Wste Mngement Regultions (VSWMR) (9VAC20-81); nd M Virgini Regultions for the Trnsporttion of Hzrdous Mterils J (9VAC20-110). b. Applicble Federl lws nd regultions include: Resource Conservtion nd Recovery Act (RCRA), 42 U.S.C. Section 6901 etseq., nd the pplicble regultions contined in Title 40 of the Code of Federl Regultions; nd U.S. Deprtment of Trnsporttion Rules for Trnsporttion of Hzrdous mterils (49 CFR Prt 107). 7. Historic nd Archeologicl Resources (see "Regultory nd Coordintion Needs," Item 9, pge 27). Section 106 of the Ntionl Historic Preservtion Act of 1966, s mended, nd its implementing regultion 36 CFR 800 requires tht federlly licensed nd permitted projects consider its effects on properties tht re listed or eligible for listing on the Ntionl Register of Historic Plces. Section 106 pplies if there is federl involvement such s the issunce of Section 404 Clen Wter Act permit, including Ntionwide Permits. The pplicbility of Section 106 to the entire project or ny portion thereof must be determined by the responsible federl gency. 8. Virgini Deprtment of Trnsporttion (VDOT) Right-of-Wy Permit (see "Regultory nd Coordintion Needs," Item 10, pge 27). The Generl Rules nd Regultions of the Commonwelth Trnsporttion Bord (24VAC30-151) re dopted pursunt to the uthority of of the Code of Virgini. These rules nd regultions provide tht no work of ny nture shll be performed on ny rel property underthe ownership, control or jurisdiction of VDOT until written permission hs been obtined from VDOT. 9. Avition (see "Regultory nd Coordintion Needs," Item 11, pge 27). Form should be submitted to the Federl Avition Administrtion if proposed development is 200 feet bove ground level or within 20,000 liner feet of public use irport pursunt to Title 14 CFR Prt 77 or if the development involves ny construction or ltertion t ny height greter thn the imginry surfces identified in the Federl Air Regultions Prt Stte Corportion Commission Considertion of Locl Comprehensive Plns (see "Regultory nd Coordintion Needs," Item 12, pge 27). The Code of Virgini Section A sttes, "In every proceeding under this subsection, the Commission shll receive nd give considertion to ll 4

7 Joel H. Peck DEQ # PUE reports tht relte to the proposed fcility by stte gencies concerned with Q environmentl protection; nd if requested by ny county or municiplity in M which the fcility is proposed to be built, to locl comprehensive plns tht hve been dopted pursunt to Article 3 ( etseq.) of Chpter 22 of Title 15.2." H w ^ p

8 Joel H. Peck DEQ # PUE SUMMARY OF FINDINGS AND RECOMMENDATIONS Bsed on the informtion nd nlysis submitted by reviewing gencies, we hve severl recommendtions for considertion by the SCC in its delibertions on the pprovl nd certifiction of electric trnsmission fcilities. These recommendtions re in ddition to requirements of federl, stte or locl lw or regultions listed bove. The rtionle for these recommendtions is discussed in the reminder of these comments, specificlly in the Environmentl Impcts nd Mitigtion section. j/l Q 0j O M in Loudoun County's Deprtment of Plnning nd Zoning recommends the selection of the proposed route to limit environmentl impcts. The Deprtment of Forestry recommends the selection of the proposed route, s it runs primrily through open lnd nd will minimlly impct forest lnds. A summry of recommendtions follows: Conduct n on-site delinetion of ll wetlnds nd strem crossings within the project re with verifiction by the U.S. Army Corps of Engineers, using ccepted methods nd procedures, nd follow DEQ's recommendtions to void nd minimize impcts to wetlnds nd strems (Environmentl Impcts nd Mitigtion, Item 1(c), pge 9). Follow DEQ's recommendtions regrding ir qulity protection, s pplicble (Environmentl Impcts nd Mitigtion, Item 4(d), pge 14). Reduce solid wste t the source, reuse it nd recycle it to the mximum extent prcticble, s pplicble (Environmentl Impcts nd Mitigtion, Item 5(c), pge 15). Coordinte with the Deprtment of Conservtion nd Recretion's (DCR) Division of Nturl Heritge regrding its recommendtions to protect nturl heritge resources s well s for updtes to the Biotics Dt System dtbse if six months hve pssed before the project is implemented (Environmentl Impcts nd Mitigtion, Item 6(e), pge 16). Coordinte with the Deprtment of Gme nd Inlnd Fisheries s necessry regrding its recommendtions to minimize impcts to wildlife nd nturl resources (Environmentl Impcts nd Mitigtion, Item 7(c), pge 17). Coordinte with the Virgini Outdoors Foundtion for further review if the project re chnges or the project does not begin within 24 months of this review (Environmentl Impcts nd Mitigtion, Item 8(c), pge 18). Coordinte with the Deprtment of Historic Resources regrding its recommendtions to protect historic nd rcheologicl resources (Environmentl Impcts nd Mitigtion, Item 11(d), pge 20).

9 Joel H. Peck DEQ # PUE Ul O M Contct the Deprtment of Trnsporttion regrding the ongoing Route 606 widening project (Environmentl Impcts nd Mitigtion, Item 12(c), pge 20). W m Follow the principles nd prctices of pollution prevention to the mximum extent prcticble (Environmentl Impcts nd Mitigtion, Item 14, pge 21). Limit the use of pesticides nd herbicides to the extent prcticble (Environmentl Impcts nd Mitigtion, Item 15, pge 22). Coordinte with Loudoun County regrding its recommendtions (Environmentl Impcts nd Mitigtion, Item 16(b), pge 24).

10 Joel H. Peck DEQ # PUE ENVIRONMENTAL IMPACTS AND MITIGATION 1. Wter Qulity nd Wetlnds. The DEQ supplement (pges 2-4) sttes tht for both the proposed route nd the lternte route, potentil wetlnd res were identified. Impcts to wetlnds during the construction of the project will be voided nd minimized to the mximum extent prcticble. The mjority of impcts to wetlnds will be temporry nd limited to the construction period. To the extent possible, the overhed trnsmission line will spn wetlnds nd the footings of structures will be instlled in uplnd res. Opertion impcts long the trnsmission line will be similr to those for n existing line nd will be limited to periodic mintennce clering of the right-of-wy. m No tidl wetlnds re ssocited with the project. Non-tidl wetlnds re likely to be present long the proposed nd lterntive routes. 1() Agency Jurisdiction. The Stte Wter Control Bord (SWCB) promulgtes Virgini's wter regultions, covering vriety of permits to include the Virgini Pollutnt Dischrge Elimintion System Permit, the Virgini Pollution Abtement Permit, the Surfce nd Groundwter Withdrwl Permit, nd the Virgini Wter Protection (VWP) Permit. The VWP permit is Stte permit which governs wetlnds, surfce wter, nd surfce wter withdrwls/impoundments. It lso serves s 401 certifiction of the federl Clen Wter Act 404 permits for dredge nd fill ctivities in wters of the U.S. The VWP Progrm is underthe Office of Wetlnds nd Strem Protection (OWSP), within the DEQ Division of Wter Permitting. In ddition to centrl office stff tht review nd issue VWP permits for trnsporttion nd wter withdrwl projects, the six DEQ regionl offices perform permit ppliction reviews nd issue permits forthe covered ctivities. 1(b) Agency Findings. The DEQ OWSP completed wetlnd impct consulttion for the proposed project on June 17, An offsite wetlnd desktop survey report ws prepred for Dominion nd submitted to DEQ. A survey of potentil impcts to wetlnds nd strems ws performed for the right-of-wy long the entire length of the preferred route. According to the submitted report, both wetlnd res nd strem corridors were identified within the proposed project route. The pproximte extent of these resources ws derived from review of U.S. Geologicl Sun/ey (USGS) 7.5 Minute Series topogrphic qudrngles, Ntionl Wetlnd Inventory mps, Nturl Resource Conservtion Service Web Soil Survey mps for the loclities within the project corridor, USGS digitl infrred orthophotogrphy, nd eril photogrphy. This report identifies non-tidl wetlnds within the project route s shown in the tble below:

11 Joel H. Peck DEQ # PUE Probbility of Wetlnd Occurrence High Medium/High Medium Medium/Low Low TOTAL Tbic I: Acrege of Probble Wetlnd Occurrence within thc ROW Totl Acres PFO N/A N/A Wetlnd Type (Acres) PSS N/A N/A PEM () PFO = plustriue forested. PSS = plustrine scrub-slmib, PEM = plustrine emergent, PUB = 0.10 N/A N/A 0.10 plustrine unconsolidted bottom (b) Thc Medium/Low nd Low probbilities did not include dt with wetlnd types. (c) The low probbility ctegory ws clculted by subtrcting hydric soils. Interpreted Wetlnds, nd NW1 dt from the ROW re. Topogrphic mp contours suggest tht ephemerl nd intermittent strems my lso be present. PUB N/A N/A m Q yi According to OWSP, detils of potentil impcts to strems nd wetlnds of the lterntive route were not provided in the submitted desktop survey report, on which DEQ's Wetlnd Impct Consulttion ws bsed. OEIR contcted OWSP on July 21, 2015 (Henicheck/Howrd emil) regrding the SCC ppliction nd DEQ Supplement submission, which did discuss both the preferred nd lterntive routes nd potentil wetlnds impcts. On July 27, 2015 OWSP confirmed tht the comments in the Wetlnd Impct Consulttion remined vlid. The DEQ Northern Regionl Office (NRO) will mke the finl permitting decisions. 1(c) Agency Recommendtions. DEQ hs the following recommendtions: Prior to commencing project work, ll wetlnds nd strems within the project corridor should be field delineted nd verified by the U.S. Army Corps of Engineers (Corps), using ccepted methods nd procedures. Wetlnd nd strem impcts should be voided nd minimized to the mximum extent prcticble. Strem impcts should be minimized or voided by spnning the trnsmission line cross ech strem. No foundtions should be plced within strembeds. Where ccess is required cross wetlnd, removble mts should be used to reduce compction nd rutting. Towers should be plced void wetlnds, wherever possible. To the extent where ny footings must be instlled in wetlnds, ech footing should occupy the minimum spce necessry. When excvtion for structure is necessry in wetlnd, excess spoil should not be disposed of in djcent wetlnd res unless uthorized by stte or federl wetlnd permit. If the scope of the project chnges, dditionl review will be necessry by DEQ OWSP.

12 Joel H. Peck DEQ # PUE At minimum, compenstion for impcts to Stte Wters, if necessry, should 0 be in ccordnce with ll pplicble stte wetlnd regultions nd wetlnd permit K5 requirements, including the compenstion for permnent conversion of forested J wetlnds to emergent wetlnds. Any temporry impcts to surfce wters ssocited with this project should require restortion to pre-existing conditions. No ctivity my substntilly disrupt the movement of qutic life indigenous to the wter body, including those species, which normlly migrte through the re, unless the primry purpose of the ctivity is to impound wter. Culverts plced in strems must be instlled to mintin low flow conditions. No ctivity my cuse more thn miniml dverse effect on nvigtion. Furthermore the ctivity must not impede the pssge of norml or expected high flows nd the structure or dischrge must withstnd expected high flows. Erosion nd sedimenttion controls should be designed in ccordnce with the Virgini Erosion nd Sediment Control Hndbook, Third Edition, These controls should be plced priorto clering nd grding nd mintined in good working order to minimize impcts to stte wters. These controls should remin in plce until the re is stbilized nd should then be removed. Any exposed slopes nd strem bnks should be stbilized immeditely upon completion of work in ech permitted re. All denuded res should be properly stbilized in ccordnce with the Virgini Erosion nd Sediment Control Hndbook, Third Edition, No mchinery my enter surfce wters, unless uthorized by Virgini Wter Protection (VWP) permit. Hevy equipment in temporrily impcted surfce wters should be plced on mts, geotextile fbric, or other suitble mteril, to minimize soil disturbnce to the mximum extent prcticble. Equipment nd mterils should be removed immeditely upon completion of work. Activities should be conducted in ccordnce with ny time-of-yer restriction(s) s recommended by the Deprtment of Gme nd Inlnd Fisheries (DGIF), the Deprtment of Conservtion nd Recretion (DCR), orthe Virgini Mrine Resources Commission (VMRC). The permittee should retin copy of the gency correspondence concerning the time-of-yer restriction(s), or the lck thereof, for the durtion of the construction phse of the project. All construction, construction ccess, nd demolition ctivities ssocited with this project should be ccomplished in mnner tht minimizes construction mterils or wste mterils from entering surfce wters, unless uthorized by permit. Wet, excess, or wste concrete should be prohibited from entering surfce wters. Herbicides used in or round ny surfce wter should be pproved for qutic use bythe U.S. Environmentl Protection Agency (EPA) orthe U.S. Fish nd Wildlife Service (FWS). These herbicides should be pplied ccording to lbel directions by licensed herbicide pplictor. A non-petroleum bsed surfctnt should be used in or round ny surfce wters. 10

13 Joel H. Peck DEQ # PUE Consider mitigting impcts to forested or converted wetlnds by estblishing new forested wetlnds within the impcted wtershed. ^ 1(d) Requirements. The following permits my be required: If the project qulifies for Ntionwide Permit 12 (NWP 12) from the Corps, then Virgini Wter Protection (VWP) permit is not necessry. If the pplicnt does not obtin NWP 12, then VWP permit my be necessry. If the project proposes permnent impcts to more thn one-hlf (1/2) cre of wetlnds, then VWP permit will be required from DEQ. A Joint Permit Appliction (JPA) for VWP permit must be submitted to DEQ for pprovl in ccordnce with 9VAC (see Item 2 in the Environmentl Impcts nd Mitigtion section for informtion on submitting JPA). 2. Subqueous Lnds Impcts. According to the DEQ supplement (pge 2), the proposed route crosses no strems. The lterntive route crosses n unnmed tributry to Brod Run. The strem crosses will be spnned by the lternte route nd no trnsmission structures will be plced in the strem. 2() Agency Jurisdiction. The Virgini Mrine Resources Commission (VMRC) regultes encrochments in, on or over stte-owned subqueous beds s well s tidl wetlnds pursunt to Virgini Code through The VMRC serves s the cleringhouse for the JPA used by the: Corps for issuing permits pursunt to Section 404 of the Clen Wter Act nd Section 10 of the Rivers nd Hrbors Act; DEQ for issunce of VWP permit; VMRC for encrochments on or over stte-owned subqueous beds s well s tidl wetlnds; nd locl wetlnds bord for impcts to wetlnds. The VMRC will distribute the completed JPA to the pproprite gencies. Ech gency will conduct its review nd respond. 2(b) Agency Comments. VMRC did not respond to the request for comment. 2(c) Agency Recommendtion. Coordinte with VMRC regrding the submittl of JPA s necessry. 3. Erosion nd Sediment Control nd Stormwter Mngement. The DEQ supplement (pge 5) sttes tht erosion nd sediment control mesures re required to be in plce priorto construction. Dominion submits erosion nd sediment control specifictions nd stormwter complince guidelines to DEQ for review nd pprovl nnully. 11 p ^ Q m p

14 Joel H. Peck DEQ # PUE () Agency Jurisdiction. The DEQ Office of Stormwter Mngement (OSWM) dministers the Virgini Erosion nd Sediment Control Lw nd Regultions (VESCL&R) nd the Virgini Stormwter Mngement Lw nd Regultions (VSWML&R). p co P M m 3(b) Agency Comments. OSWM did not comment on the proposed project; however regultory guidnce on erosion nd sediment control nd stormwter mngement is provided below, bsed on pst comments on similr electricl utility projects. 3(b)(i) Erosion nd Sediment Control Annul Specifictions, Stormwter Mngement nd Locl Progrm Complince. In ccordnce with et seq., electric, nturl gs nd telephone utility compnies, interstte nd intrstte nturl gs pipeline compnies, nd rilrod compnies shll, nd uthorities creted pursunt to my, file generl erosion nd sediment control stndrds nd specifictions nnully with DEQ for review nd pprovl. Such stndrds nd specifictions shll be consistent with the requirements of this rticle nd ssocited regultions nd the Erosion nd Sediment Control Lw nd Stormwter Mngement Act ( :24 etseq.) nd ssocited regultions where pplicble. The specifictions shll pply to: Construction, instlltion, or mintennce of electric trnsmission, nturl gs, nd telephone utility lines nd pipelines, nd wter nd sewer lines; nd Construction of the trcks, rights-of-wy, bridges, communiction fcilities, nd other relted structures nd fcilities of the rilrod compny. 3(b)(ii) Generl Virgini Pollutnt Dischrge Elimintion System (VPDES) Permit for Dischrges of Stormwter from Construction Activities (VAR10). The opertor or owner of construction ctivity involving lnd disturbnce of equl to or greter thn 1 cre is required to register for coverge underthe Generl VPDES Permit for Dischrges of Stormwter from Construction Activities nd develop project specific stormwter pollution prevention pln (SWPPP). The SWPPP must be prepred priorto submission of the registrtion sttement for coverge under the generl permit nd the SWPPP must ddress wter qulity nd quntity in ccordnce with the Virgini Stormwter Mngement Progrm (VSMP) Regultions. Generl informtion nd registrtion forms forthe Generl Permit re vilble t ctiongenerlpermit. spx. 4. Air Qulity. The DEQ supplement (pge 2) sttes tht Dominion does not expect to burn clered mteril nd does not expect significnt impcts on ir qulity. Fugitive dust will be controlled during construction in ccordnce with DEQ regultions. There my be temporry impcts to ir qulity during construction due to the use of hevy mchinery nd the potentil for irborne debris. 12

15 Joel H. Peck DEQ # PUE () Agency Jurisdiction. DEQ's Air Division, on behlf of the Stte Air Pollution Control Bord, is responsible for developing regultions tht implement Virgini's Air Pollution Control Lw. DEQ is chrged with crrying out mndtes of the stte lw nd relted regultions s well s Virgini's federl obligtions under the Clen Air Act s mended in The objective is to protect nd enhnce public helth nd qulity of life through control nd mitigtion of ir pollution. The division ensures the sfety nd qulity of ir in Virgini by monitoring nd nlyzing ir qulity dt, regulting sources of ir pollution, nd working with locl, stte nd federl gencies to pln nd implement strtegies to protect Virgini's ir qulity. The pproprite regionl office is directly responsible forthe issunce of necessry permits to construct nd operte ll sttionry sources in the region s well s monitoring emissions from these sources for complince. As prt of this mndte, environmentl impct reports of projects to be undertken in the stte re lso reviewed. In the cse of certin projects, dditionl evlution nd demonstrtion must be mde underthe generl conformity provisions of stte nd federl lw. 4(b) Ozone Nonttinment Are. According to the DEQ Air Division, the project site is locted in n ozone nonttinment re nd n emission control re for voltile orgnic compounds (VOCs) nd oxides of nitrogen (NOx), which re contributors to ozone pollution. y»l m H o M 4(c) Requirements. 4(c)( i) Fugitive Dust During construction, fugitive dust must be kept to minimum by using control methods outlined in 9VAC et seq. of the Regultions for the Control nd Abtement of Air Pollution. These precutions include, but re not limited to, the following: Use, where possible, wter or chemicls for dust control; Instll nd use hoods, fns nd fbric filters to enclose nd vent the hndling of dusty mterils; Cover open equipment for conveying mterils; nd Promptly remove spilled or trcked dirt or other mterils from pved streets nd remove dried sediments resulting from soil erosion. 4(c)(ii) Open Burning. If project ctivities chnge to include open burning or the use of specil incinertion devices re employed in the disposl of lnd-clering debris during demolition nd construction, these ctivities must meet the requirements under 9VAC5-130 etseq. for open burning. Wheres, the regultion provides for, but does not require, the locl doption of model ordinnce concerning open burning, Dominion should contct the loclity to determine wht locl requirements, if ny, exist. Some pplicble provisions of the regultion include, but re not limited to: All resonble effort shll be mde to minimize the mount of mteril burned, with the number nd size of the debris piles; The mteril to be burned shll consist of clen burning demolition mteril; 13

16 Joel H. Peck DEQ # PUE The burning shll be t lest 500 feet from ny occupied building unless the occupnts hve given prior permission, other thn building locted on the property on which the burning is conducted; The burning shll be conducted t the gretest distnce prcticble from highwys nd irfields; The burning shll be ttended t ll times nd conducted to ensure the best possible combustion with minimum of smoke being produced; The burning shll not be llowed to smolder beyond the minimum period of time necessry for the destruction of the mterils; nd The burning shll be conducted only when the previling winds re wy from ny city, town or built-up re. p p KJ J 4(c)(iii) Asphlt Pving. In ccordnce with 9 VAC ef seq., there re limittions on the use of "cut-bck" (liquefied sphlt cement, blended with petroleum solvents) tht my pply to pving ctivities ssocited with the project. Moreover, there re time-of-yer restrictions on its use during the months of April through October in VOC emission control res. 4(c)(iv) Fuel-burning Equipment. The DEQ NRO sttes tht, should the project instll fuel burning equipment (boilers, genertors, compressors, etc.), or ny other ir pollution emitting equipment, the project my be subject to 9 VAC 5-80, Article 6, Permits for New nd Modified sources. 4(d) Agency Recommendtions. Contct the Air Permit Mnger t DEQ-NRO prior to instlltion or construction, nd opertion, of fuel burning or other ir pollution emitting equipment for permitting determintion. Ensure tht precutions re tken to restrict the emissions of VOCs nd NOx- 5. Solid nd Hzrdous Wste Mngement. The DEQ supplement (pge 4) sttes tht dtbse serch of informtion vilble from the U.S. Environmentl Protection Agency (EPA) nd DEQ ws performed, including Geogrphic Informtion System (GIS) serch. The serch did not find ny superfund sites on the Ntionl Priorities List within the vicinity of the project. One Voluntry Remedition Progrm (VRP) site ws identified pproximtely six miles northest of the project re in Sterling, Virgini. None of the identified wste sites re within the right-of-wy of the routes under considertion. Cre will be tken to operte nd mintin construction equipment to prevent ny fuel or oil spills. Any wste creted by construction crews will be disposed of properly. 5() Agency Jurisdiction. Solid nd hzrdous wstes in Virgini re regulted by DEQ, the Virgini Wste Mngement Bord nd the Environmentl Protection Agency (EPA). They dminister progrms creted by the federl Resource Conservtion nd Recovery Act (RCRA), Comprehensive Environmentl Response Compenstion nd Libility Act (CERCLA), commonly clled Superfund, nd the Virgini Wste 14

17 Joel H. Peck DEQ # PUE Mngement Act. DEQ dministers regultions estblished by the Virgini Wste Mngement Bord nd reviews permit pplictions for completeness nd conformnce with fcility stndrds nd finncil ssurnce requirements. All Virgini loclities re required, under the Solid Wste Mngement Plnning Regultions, to identify the strtegies they will follow on the mngement of their solid wstes to include items such s fcility siting, long-term (20-yer) use, nd lterntive progrms such s mterils recycling nd composting. JJI JJ p ^ M ijn 5(b) Dtbse nd Dt File Serch. The DEQ Division of Lnd Protection nd Revitliztion (DLPR) sttes the ppliction indictes tht serch of both solid nd hzrdous wste dtbses hd been completed. DEQ's DLPR stff conducted cursory dtbse serch of zip code nd found no wste sites in close proximity to the project corridor. 5(c) Agency Recommendtions. DEQ encourges ll projects nd fcilities to implement pollution prevention principles, including: the reduction, reuse nd recycling of ll solid wstes generted; nd the minimiztion nd proper hndling of generted hzrdous wstes. 5(d) Requirements. Any soil tht is suspected of contmintion or wstes tht re generted during construction must be tested nd disposed of in ccordnce with pplicble federl, stte nd locl lws nd regultions. Contct DEQ if improperly disposed solid or hzrdous wstes, or petroleum contminted soils, re encountered during construction nd follow pplicble federl, stte nd locl regultions for disposl. If pplicble, ll structures being demolished should be checked s pproprite for sbestos-contining mterils (ACM) nd led-bsed pint (LBP) priorto demolition. If ACM or LBP re found, in ddition to the federl wste-relted regultions mentioned bove, stte regultions 9VAC for ACM nd 9VAC for LBP must be followed. All solid wstes, hzrdous wstes, nd hzrdous mterils, including construction nd demolition wstes nd universl wstes must be mnged in ccordnce with ll pplicble federl, stte, nd locl environmentl regultions. 6. Nturl Heritge Resources. According to the DEQ supplement (pge 5), the potentil for impcts to the hbitt of rre, thretened, or endngered plnt nd niml species is expected to be low, bsed on.the inclusion of n existing right-of-wy for the project. 15

18 Joel H. Peck DEQ # PUE () Agency Jurisdiction. 6()(i) Agency Jurisdiction Nturl Heritge Resources. The mission of DCR is to conserve Virgini's nturl nd recretionl resources. The DCR DNH mission is to conserve Virgini's biodiversity through inventory, protection nd stewrdship. The Virgini Nturl Are Preserves Act, through 217 of the Cocfe of Virgini, ws pssed in 1989 nd codified DCR's powers nd duties relted to sttewide biologicl inventory: mintining sttewide dtbse for conservtion plnning nd project review, lnd protection for the consen/tion of biodiversity, nd the protection nd ecologicl mngement of nturl heritge resources (the hbitts of rre, thretened, nd endngered species, significnt nturl communities, geologic sites, nd other nturl fetures). 6()(ii) Agency Jurisdiction Thretened nd Endngered Plnt nd Insect Species. The Endngered Plnt nd Insect Species Act of 1979, Chpter through 1030 of the Code of Virgini, s mended, uthorizes Virgini Deprtment of Agriculture nd Consumer Services (VDACS) to conserve, protect nd mnge endngered nd thretened species of plnts nd insects. The VDACS Virgini Endngered Plnt nd Insect Species Progrm personnel coopertes with the FWS, DCR DNH nd other gencies nd orgniztions on the recovery, protection or consen/tion of listed thretened or endngered species nd designted plnt nd insect species tht re rre throughout their worldwide rnges. In those instnces where recovery plns, developed by FWS, re vilble, dherence to the order nd tsks outlined in the plns re followed to the extent possible. VDACS hs regultory uthority to conserve rre nd endngered plnt nd insect species through the Virgini Endngered Plnt nd Insect Species Act. Under Memorndum of Agreement estblished between the VDACS nd DCR, DCR hs the uthority to report for VDACS on stte-listed thretened nd endngered plnt nd insect species. 6(b) Agency Findings. The DCR DNH serched its Biotics Dt System (Biotics) for occurrences of nturl heritge resources from the re outlined on the submitted mp. According to the informtion currently in Biotics, nturl heritge resources hve not been documented within two miles of the project re. The bsence of dt my indicte tht the project re hs not been surveyed, rther thn confirm tht the re lcks nturl heritge resources. 6(c) Thretened nd Endngered Plnt nd Insect Species. According to DCR DNH the current ctivity will not ffect ny documented stte-listed plnts or insects. 6(d) Nturl Are Preserves. DCR DNH sttes tht there re no Nturl Are Preserves under its jurisdiction in the project vicinity. 6(e) Agency Recommendtions. Contct the DCR DNH to re-submit project informtion nd mp for n updte on this nturl heritge informtion if the scope of the project chnges nd/or six months hs pssed before it is utilized. 16

19 Joel H. Peck DEQ # PUE Wildlife Resources. The DEQ supplement (pge 4) indictes tht Dominion o coordinted directly with DGIF regrding thretened nd endngered species. Certin SO federl-listed nd stte-listed species were identified s potentilly occurring in the project re. Dominion will coordinte with DGIF nd DCR s pproprite to determine um whether surveys re necessry nd to minimize impcts on wildlife resources. 7() Agency Jurisdiction. DGIF, s the Commonwelth's wildlife nd freshwter fish mngement gency, exercises enforcement nd regultory jurisdiction over wildlife nd freshwter fish, including stte- or federlly-listed endngered or thretened species, but excluding listed insects (Virgini Code Title 29.1). DGIF is consulting gency underthe U.S. Fish nd Wildlife Coordintion Act (16 U.S.C. sections 661 et seq.) nd provides environmentl nlysis of projects or permit pplictions coordinted through DEQ nd severl other stte nd federl gencies. DGIF determines likely impcts upon fish nd wildlife resources nd hbitt, nd recommends pproprite mesures to void, reduce or compenste for those impcts. 7(b) Agency Findings. DGIF commented tht listed wildlife or designted resources under its jurisdiction re not currently documented in the project re. Adverse impcts upon such species nd resources re not nticipted. 7(c) Agency Recommendtions. To minimize the dverse impcts of liner utility project development on wildlife resources, DGIF offers the following generl recommendtions: o Avoid nd minimize'impcts to undisturbed forest, wetlnds nd strems to the fullest extent prcticble, o Mintin nturlly vegetted buffers of t lest 100 feet in width round ll on-site wetlnds nd on both sides of ll perennil nd intermittent strems, where prcticble, o Conduct significnt tree removl nd ground clering ctivities outside of the primry songbird nesting seson of Mrch 15 through August 15. o Implement nd mintin pproprite erosion nd sediment controls throughout construction of the project nd site restortion. DGIF will work with the pplicnt to develop project-specific mesures s necessry to minimize project impcts upon wildlife resources. 8. Virgini Outdoors Foundtion. According to Section V. "Notice" of the SCC ppliction, Dominion coordinted directly with the Virgini Outdoors Foundtion (VOF) in My 2015 nd n electronic copy of the ppliction ws provided. 8() Agency Jurisdiction. The Virgini Outdoors Foundtion (VOF) ws creted by the Generl Assembly in 1966 nd estblished in the Code of Virgini under , which sttes:" The Virgini Outdoors Foundtion is estblished to promote the preservtion of open-spce lnds nd to encourge privte gifts of money, securities, lnd or other property to preserve the nturl, scenic, historic, scientific, open-spce nd recretionl res of the Commonwelth. The Virgini Outdoors Foundtion is 17 H ^ Q ^

20 Joel H. Peck DEQ # PUE body politic nd shll be governed nd dministered by bord of trustees composed of seven trustees from the Commonwelth t lrge to be ppointed by the Governor for four-yer terms." 8(b) Agency Comments. The VOF reviewed the projects nd stted tht s of June 22, 2015, there re no existing or proposed VOF open-spce esements within the immedite vicinity of the project. gn so w 8(c) Agency Recommendtion. Contct the VOF for further review if the project re chnges or if the project does not begin within 24 months of this review. 9. Forest Resources. The DEQ Supplement (pge 7) sttes tht the proposed project is expected to hve miniml impct on forest resources. Dominion's tree clering methods utilize the DOF's Best Mngement Prctices for Wter Qulity. 9() Agency Jurisdiction. The mission of the DOF is to protect nd develop helthy, sustinble forest resources for Virginins. DOF ws estblished in 1914 to prevent nd suppress forest fires nd reforest bre lnds. Since the Deprtment's inception, it hs grown nd evolved to encompss other protection nd mngement duties including: protecting Virgini's forests from wildfire, protecting Virgini's wters, mnging nd conserving Virgini's forests, mnging stte-owned lnds nd nurseries, nd mnging regulted incentive progrms for forest lndowners. 9(b) Agency Finding. DOF stted tht bsed on the informtion provided nd n inteml GIS review, DOF grees with the preferred new right-of-wy route option for the trnsmission line. It is only 4/10 of mile, nd runs through primrily open lnd. Some tree removl will be required but tht is miniml. The procedures proposed for tree removl nd ongoing mintennce in the right-of-wy corridor once the line is built re in keeping with DOF Forestry Best Mngement Prctices nd SCC environmentl guidelines for power line right-of-wys. 9(c) Agency Recommendtion. DOF recommends the selection of the proposed (preferred) route rther thn the lternte route, s it hs miniml impct on forest lnds nd minimizes lnd clering. 10. Recretionl Resources. The DEQ supplement (pge 7) indictes tht the project is expected to hve miniml impct on recretionl resources. There is one prk within the vicinity of the proposed project, mintined by Loudoun County Deprtment of Prks nd Recretion nd Community Services. The proposed route is 0.4 mile from the Areol Slve Qurters, while the lternte route is 0.3 mile from the resource. The document indictes tht Dominion coordinted with DCR's Division of Plnning nd Recretionl Resources (DPRR) nd the division hd no comments on the project. 10() Agency Jurisdiction. The DCR Division of Plnning nd Recretionl Resources (DPRR), develops the Virgini Outdoors Pln nd coordintes brod rnge of recretionl nd environmentl progrms throughout Virgini. These progrms include 18

21 Joel H. Peck DEQ # PUE the Virgini Scenic Rivers progrm, Trils, Greenwys, nd Bluewys; Virgini Stte Prk Mster Plnning; nd Stte Prk Design nd Construction. 10(b) Agency Findings. The DCR DPRR hd no comments on the proposed ction. yi fo Q 11. Historic nd Archeologicl Resources. The DEQ supplement (pges 5-6) ddresses potentil impcts to historic nd rcheologicl resources. A pre-ppliction nlysis ws completed on My 12, 2015 nd ws provided to DHR. No Ntionl Historic Lndmrk properties were found within 1.5 miles of the proposed project's rightof-wy. Two properties listed on the Ntionl Register of Historic Plces (NRHP) were found within one mile of the proposed route right-of-wy nd five properties tht re potentilly eligible for listing on the NRHP were found within hlf mile of the project. The lternte route would hve two NRHP listed properties within one mile of the proposed project right-of-wy nd seven properties tht re potentilly eligible for listing within hlf mile. 11() Agency Jurisdiction. The Deprtment of Historic Resources (DHR) conducts reviews of projects to determine their effect on historic structures or culturl resources under its jurisdiction. DHR, s the designted Stte's Historic Preservtion Office, ensures tht federl ctions comply with Section 106 of the Ntionl Historic Preservtion Act of 1962 (NHPA), s mended, nd its implementing regultion t 36 CFR Prt 800. The NHPA requires federl gencies to consider the effects of federl projects on properties tht re listed or eligible for listing on the Ntionl Register of Historic Plces. Section 106 lso pplies if there re ny federl involvements, such s licenses, permits, pprovls or funding. DHR lso provides comments to DEQ through the stte environmentl impct report review process. 11(b) Agency Comments. DHR sttes tht Dominion hs been in direct consulttion with DHR nd hs previously coordinted the results of the Pre-Appliction Anlysis in ccordnce with DHR's Guidelines for Assessing Impcts of Proposed Electric Trnsmission Lines nd Associted Fcilities on Historic Resources in the Commonwelth of Virgini (2008) (Guidelines). Dominion's pre-ppliction nlysis considered the potentil impct of the proposed project on recorded historic resources tht re listed or those previously determined eligible for listing in the Virgini Lndmrks Register (VLR) nd the Ntionl Register of Historic Plces within tiered study re. DHR's comments re provided s technicl ssistnce to DEQ nd the SCC in the review of this ppliction. DHR sttes tht it hs not been notified by ny federl gency of its involvement in this project; however, DHR reserves the right to provide dditionl comment pursunt to the Ntionl Historic Preservtion Act, if pplicble. 11(c) Agency Findings. The project will hve miniml impcts to recorded VLR/NRHP listed/eligible properties. 19

22 Joel H. Peck DEQ # PUE (d) Agency Recommendtion. DHR recommends the following: Conduct comprehensive rcheologicl nd rchitecturl surveys in ccordnce with DHR Guidelines using qulified professionls priorto construction of ny SCC-pproved ltemtive. Evlute resources identified for listing in the VLR nd NRHP. Assess potentil direct nd indirect impcts to ll eligible nd listed resources of the VLR nd NRHP. Avoid, minimize nd/or mitigte moderte to severe impcts to eligible nd listed resources of the VLR nd NRHP in consulttion with DHR nd other stkeholders. p tfi ^ ^ p VI 11(e) Requirement. If there is ny federl involvement, Dominion should coordinte the project or ny portion thereof with the responsible federl gency nd DHR to ensure complince with Section 106 of the Ntionl Historic Preservtion Act, s mended, nd its implementing regultions t 36 CFR Trnsporttion Impcts. According to the DEQ supplement (pges 8), both the proposed route nd the lternte route will hve one rod crossing- Areol Rod. Where conductors cross rodwys, Dominion will mintin proper clernces between the rod surfces nd the conductors. Dominion will comply with Virgini Deprtment of Trnsporttion (VDOT) permits nd requirements for eril crossings nd for when ccess to the electric trnsmission rightof-wy from public rods is required. 12() Agency Jurisdiction. The VDOT provides comments pertining to potentil impcts to existing nd future trnsporttion systems. 12(b) Agency Findings. According to the VDOT Northern Virgini (NOVA) District Office, the proposed project does not involve use of ny stte/federl trnsporttion funds. VDOT's uthority is for ccessing the right-of-wy through the VDOT Lnd Use Permit Process. 12(c) Agency Recommendtions. Ensure tht the design nd construction of the proposed power line is dequtely coordinted with VDOT's ongoing Route 606 widening project (in ccordnce with the Loudoun County Trnsporttion Pln). 12(d) Requirements. Dominion is responsible for securing ll necessry wter qulity permits, including nturl nd historic resource clernces, from federl nd/or stte regultory gencies forthe proposed project on VDOT right-of-wy; Construction within VDOT right-of-wy shll be conducted in ccordnce with pplicble federl nd stte lws, regultions nd project-specific permit provisions tht pply; 20

23 Joel H. Peck DEQ # PUE m JL J Erosion nd sediment control design plns must be pproved nd reviewed by ^ the DEQ or the delegted pln pprovl uthority; nd k2 Comply with the VDOT Rod nd Bridge Specifiction () for Erosion nd Sediment Control Contrctor Certifiction for lnd-disturbing ctivities in the VDOT right-of-wy. 13. Avition Impcts. The DEQ Supplement (pge 8-9) indictes tht Dulles Airport is in the vicinity of the project. The proposed route is locted ner but not on the Metropolitn Wshington Airports Authority's property. An irspce restriction nlysis ws completed nd the proposed line ws found to cross two published pproch surfces for the existing runwy 12; however, neither the proposed or ltemte routes would exceed the obstruction surfce for this pproch. As result it ws determined tht there would be no significnt height restrictions (no structures required to be less thn 110 feet bove ground level) for the proposed Yrdley Ridge trnsmission line. 13() Agency Jurisdiction. The Virgini Deprtment of Avition is stte gency tht plns for the development of the stte vition system; promotes vition; grnts ircrft nd irports licenses; nd provides finncil nd technicl ssistnce to cities, towns, counties nd other governmentl subdivisions forthe plnning, development, construction nd opertion of irports, nd other vition fcilities. 13(b) Agency Finding. The proposed project ppers to be within 20,000 liner feet of Dulles Interntionl Airport (Dulles). Therefore, 7460 form must be submitted to the FAA to determine if the proposed development will constitute hzrd to ir nvigtion. 13(c) Requirements. Submit 7460 Form to the FAA for review for ny portion of the project tht results in construction occurring within 20,000 liner feet of ny public-use irport or ny structure tht exceeds 200 feet bove ground level pursunt to Title 14 Code of Federl Regultions Prt (d) Agency Conclusion. Provided the FAA determines the proposed project does not constitute hzrd to ir nvigtion nd the development does not result in n increse to pproch minimums, the DoAV hs no objection to the project. If the FAA determines tht the proposed development results in either n increse to the pproch minimums into Dulles or constitutes hzrd to ir nvigtion, then the DoAV cnnot support the project s submitted. 14. Pollution Prevention. DEQ dvoctes tht principles of pollution prevention be used in ll construction projects. Effective siting, plnning nd on-site best mngement prctices will help to ensure tht environmentl impcts re minimized. Pollution prevention techniques lso include decisions relted to construction mterils, design nd opertionl procedures tht fcilitte the reduction of wstes t the source. We hve severl recommendtions regrding pollution prevention: 21