How to Review an Environmental Impact Statement

Guest Blog | February 12, 2015 | Energy Policy, Wind

This blog is the first in a series reviewing the proposed Plains and Eastern Clean Line project. Other blogs in the series will be available here when published.

The Plains and Eastern Clean Line, a high voltage direct current transmission project, would connect more than 3,500 megawatts of high quality, low cost wind power from western Oklahoma and Texas deep into Arkansas and Tennessee. The 720 mile long power line is presently undergoing a federal environmental impact statement review by the U.S. Department of Energy (DOE). A draft version of that review has been published and the public has until March 19th to provide comments. Weighing in at 3,700 pages, the hulking review document exhaustively covers just about any impact the project may have. How can anyone read that much and still provide valuable comments on the project? Here’s a few quick tips to help review the Plains and Eastern Clean Line EIS in order to provide good quality comments.

1. Learn how the project is broken up into different parts.

Generally, the project is broken up into four parts: three converter stations (one each in Oklahoma, Arkansas and Tennessee), the HVDC system, the AC transmission “collection” system, and the wind farms connected. Each part has many subparts (Region 2, Converter station Optima, etc.), but generally impacts stem from these four larger portions. Each part of the project can have unique impacts, so it’s important to remember to review all the parts.

2. Learn the hierarchy of the EIS.

The Draft EIS has an 84 page summary. Start there. The full EIS is broken up into five “volumes.” Each volume contains many chapters, or appendices. Generally, each chapter covers one broad topic. There are different chapters on agriculture, air and climate change, electrical environment, environmental justice, geology, soils & minerals, groundwater, health & safety, historic and cultural resources, land use, noise, recreation, socioeconomics, special status species, surface water, transportation, vegetation, visual resources, wetlands, floodplains, & riparian, wildlife, fish, & aquatics and cumulative impacts. Recognize that if the Department of Energy wrote on a topic, that does not necessarily mean that the Plains and Eastern Clean Line Project will cause irreversible harm regarding that particular topic; instead, recognize that the DOE evaluated the topic, and that you’ll need to read a particular section to see the analysis.

3. Focus on the impacts.

Portions of the beginning of each chapter contain substantial amounts of background information. As the information is presented, minimalistic analysis is provided with a lot of qualifiers (“may”, “could” and “potential” are good qualifying terms). But the actual “impact statement” tends to be towards the end of each chapter under a subheading, “Impacts to…”. The impacts are then further analyzed between “Unavoidable and Adverse Impacts” and “Irreversible and Irretrievable” resources lost. The EIS recognizes that most of the impacts of the project are of the “local short-term” sorts, and many of those impacts can be avoided or reversed, making the adverse and irreversible impacts few, but important. For a summary of impacts, Chapter 2 has a fairly exhaustive list, but not necessarily a complete quantification of impacts.

4. Get help.

If you read at a rate of 1 page per 2 minutes, it’d take about 123 hours of nonstop reading to complete the document. The document itself can be extremely technical and includes discussions on seismic hazards, stream water quality, race and poverty, sound levels, socioeconomics and a whole host of other issues and topics in fine detail. Even if a person were to read the full document, chances are that one person is not an expert on all the topics covered, and the amount of time necessary to become an expert would likely surpass the comment period deadline. Recognize that you’re unlikely to read the full document without some help.

5. Focus on issues that you either have an expertise in, or are most interested in.

Not everyone is interested in the number of jobs the project could create, or the types of soil in the project right of way, or even what electromagnetic fields are. To quickly find what you are looking for, first use the tables of content, then open up a chapter and use the “search” or “find” function in your PDF viewer. This is a simple trick that evidently some 90% of internet users haven’t ever heard of.

6. Keep a list of terms and acronyms handy.

EPMs, BMPs, HDVC…The Glossary is Chapter 7, and it alone is 20 pages long.

7. When writing your comments, make the Department of Energy’s job easy.

There are two ways to help out the Department of Energy. The first way is to completely ignore the EIS and write whatever you want. Asking a lot of questions and making unsubstantiated claims will make it a lot easier for the DOE dismiss your comments. The second and preferred way to help the DOE is by thoroughly reading (a portion of) the EIS, cite specific portions of it, and providing credible research. Do your and their homework.

Assuredly, there are other ways to review an EIS, but hopefully this provides a good head start. If, after reading this blog, you would like to submit a public comment supporting the Clean Line project, click here.

This blog is part of a series reviewing the proposed Plains and Eastern Clean Line project. 


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