Let's move on to FERC's new rules for permitting transmission projects in a National Interest Electric Transmission Corridor.  FERC also released this rule on Monday.  It's another instance of FERC batting away any constructive criticism and doubling down on a bad idea.  What's in the water down there anyhow?

If the U.S. Department of Energy designates a National Interest Electric Transmission Corridor, and a transmission project is planned for that corridor, first the transmission developer must attempt to get state permits for its project.  In the event that a state denies a permit for a project, then the transmission developer can go to FERC, denial in hand, and ask that FERC overrule the state and site and permit the transmission project anyhow.

This may be the situation with MARL, and any other transmission project that DOE creates a corridor for.

FERC was given authority to site and permit transmission as a "backstop" to state inaction back in 2005.  FERC subsequently created rules for its process to do so.  When Congress changed the "backstop" law in 2021 to allow FERC to permit even when a state denied a project, FERC released a rulemaking to update its process.  During the rulemaking, FERC received numerous comments on its proposed rule and suggestions to make it better.  Across the board, FERC rejected most of these changes.

If you find yourself in a situation where the project you oppose ends up before FERC, you're going to need to know the rules for participating in that process.

FERC made only one useful concession between its proposed rule and the final rule issued on Monday.   The proposed rule allowed a transmission developer to begin the pre-filing process at FERC at the same time it filed its applications with state commissions.  That idea, which was widely panned by states and landowners, would have required landowners to participate in the FERC process at the same time as the state process.  Two permitting processes, two sets of rules, two sets of lawyers, two sets of headache.  All with the knowledge that the FERC process would become unnecessary if the state approved the project.  A complete waste of time.  However, FERC dumped that proposed rule and now says that a developer cannot begin its pre-filing until one year AFTER it files its state applications.  This gives the state a year to complete its permitting before the FERC process begins.  At least you won't be engaging in two permitting processes at the same time.  However, FERC did not speak to landowners' question regarding whether the FERC process would proceed while state appeals are pending.  For instance, if a state denies, the transmission developer could appeal that denial in state court, instead of engaging in the more expensive and lengthy FERC process.  Conversely, if a state approved and the landowners appealed that decision, when would the FERC process begin?  This means that this process is still subject to being shaped in practice.

The part of FERC's new rule that is truly awful is its insistence that an "Applicant Code of Conduct" will ensure that the transmission owner has "made good faith efforts to engage with landowners and other stakeholders early in the permitting process" as required by the statute.h

FERC has turned this into a box-checking exercise, not an actual determination of whether the transmission developer has complied with any "Code", as specious as it is.  The "Code" is generalized garbage and anyone who has ever had to deal with a transmission developer land agent would be able to drive a truck through its many holes.  It's not like any "Code of Conduct" you've ever seen used on any transmission project.  In fact, it's so short and devoid of any landowner protections, I can copy the whole thing right here. Applications 

That's all the "protection" you get.  As long as a transmission developer files this and says it will follow it, then the box is checked and the transmission developer is "acting in good faith" no matter what it does.  "Avoiding" certain behavior is not the same as prohibiting it.  

Compare this crappy "protection" to what a group of experienced transmission opponents asked FERC to do in their comments.

You can expect to experience the same things landowners described in their comments, not FERC's rosy "landowner protections," which do little to actually protect landowners.  FERC believes that its "success" permitting natural gas pipelines will ensure landowners are treated fairly in the process.  If FERC's future permitting of electric transmission lines is anything like it's prior permitting for natural gas pipelines, we'd all better learn the words to this song:

FERC has chosen to become, in the words of Impacted Landowners, "...just another flashpoint that draws protestors to the Commission’s headquarters because the people understand they have been stripped of the last vestige of any fair process to defend their rights by a federal agency captured by the industry it is supposed to regulate."

​See you at FERC, friends.  Bring your singing voice!

Lots of people concerned about the U.S. Department of Energy's preliminary National Interest Electric Transmission Corridors (NIETC) attended DOE's webinar on Thursday afternoon.  The DOE gals were just so enthusiastic and CHEERY about the whole thing, like little hens proudly showing off their chicks.  Don't they realize what these enormous "corridors" represent to their audience?  They represent appropriation and forced taking of private property.  Nobody was buying the forced cheer.  One person asked me if it was some sort of public relations stunt.  I received a lot of comments afterwards, none of them good.  Is DOE really that detached from the reality of their actions?  The whole shebang was nothing but a clueless charade.

One of them said NIETCs were "likely to catalyze" new transmission, but the only thing being catalyzed on Thursday afternoon was confusion and anger.  It was only DOE's hubris that made them think they could manipulate all the victims into advocacy, or at least acceptance.

​Here's DOE's idea of the "impact" of designation. 

Let's concentrate on the graphics they used.  Profits (for transmission developers) are solved by making deals.  The words weren't necessary.  Clueless.  Absolutely no thought about how their presentation may be perceived by the public.

These corridors are supposed to facilitate "national energy policy" which, at this time, is supposed to be carbon reduction.  But then there was this:

One of these projects is NOT for clean energy... at all.  In fact, it will increase carbon emissions by sourcing new energy for Northern Virginia's data centers from coal-fired generators in West Virginia.  How did that get on the list?  And where has DOE proven anything on this chart?  Truth is that building this much transmission is only going to cause consumer costs to go up.  Adding new costs does not result in lower prices.  It's all made up.

And how about those not-to-scale, featureless maps?

Those lines are supposed to be two miles wide, but they're much, much bigger as shown on the maps.  We need accurate maps or written descriptions of the corridors so we can figure out where exactly they are supposed to be.  And where did all those new segments come from, exactly?  This isn't one transmission project, it's many.  How much coal power does DOE think data centers need?  Who asked DOE to plan these additional routes that PJM rejected last year?

DOE says it received information from "the public" or maybe it was "interested parties" in Phase 1 of its process that created these corridors, but we're not allowed to see any of it.  When your government is conspiring behind closed doors with corporations who stand to profit from these plans, what's the point of public consultation anyhow?

Here's a little reality for DOE.

DOE is not a grid planner.  It doesn't have the knowledge, expertise, or authority.  None of DOE's corridor plans have to be used for new transmission.  It's just a corporate wish list.

DOE is not a transmission regulator.  It has no authority to permit anything in these made up corridors.  There is no guarantee that state utility commissions, or even FERC, will agree that these corridors are transmission that needs to be built.

DOE is not a transmission router.  It has no knowledge, expertise or authority to site transmission projects.  There's a lot more than drawing lines on a map that goes into routing transmission lines.  It is likely that DOE made a bunch of huge and unrecoverable mistakes within these corridors that prevent transmission from ever being sited within.

The veneer of DOE's charade was pretty thin for me on Thursday.  I wonder if they would be so cheery if they knew that there's little chance of their scheme surviving regulatory and judicial review?  But pretending to be serious academics who have all the answers sure was fun, wasn't it?

At least there's one Senator interested in helping his constituents with NIETCs!  Bravo!

Yesterday, Missouri Senator Josh Hawley sent a letter to DOE Secretary Granholm.

Hawley also introduced legislation called the Protecting Our Farmers from the Green New Deal Act meant to:

That would pretty much put an end to NIETCs.

Let's hope other elected officials follow Senator Hawley's lead and care more about their constituents than they do about the "Green New Deal."

Here's a little extra help planning your comments on the U.S. Department of Energy's preliminary Midwest-Plains corridor that follows the route of the Grain Belt Express across Kansas, Missouri, and Illinois.

Even though GBE's right-of-way is roughly 200 feet wide, DOE's National Interest Electric Transmission Corridor is 5 miles wide.  FIVE MILES!  It will engulf entire farms!

DOE says this corridor is needed for "clean energy" but it fails to even acknowledge Grain Belt Express.  Grain Belt Express claims to have all the approvals it needs to build the project already.  Why the corridor?  Are there going to be more projects routed in that corridor, slowly swallowing up farm after farm?  Or is the corridor somehow needed for GBE to get the taxpayer-guaranteed financing it has been seeking?

Designation of a NIETC in this corridor will require an enviromental impact statement for the entire corridor.  GBE already has an EIS in process for its federal loan application, but it's just for the narrow right-of-way needed for GBE.  A whole new EIS will be required for a 5-mile corridor.  Is this why GBE's EIS seems to have been forgotten?

At any rate, here's my advice on submitting effective comments.  It's very similar to the EIS comments you may have submitted several years ago.  Make sure you have also sent your extension request and letters to elected officials for Step 1.

DOE’s announcement of proposed corridors begins Phase 2 of its process.

DOE has not provided information about why it is considering a corridor for Grain Belt Express, since the project is claiming to have all the state approvals it needs. It is unclear whether this corridor is a requirement for Grain Belt’s approval of a government-guaranteed loan and how corridor designation would impact the ongoing Environmental Impact Statement process underway by DOE.

Phase 2 allows “information and recommendations” and comment from any interested party and you are urged to submit your comments.

DOE requests information submissions in Phase 2 by 5:00 pm on June 24, 2024. Interested parties may email comments as attachments to [email protected]. You are encouraged to request DOE acknowledge your submission by return email so that you know it was received by the deadline. DOE requests comments in Microsoft Word or PDF format, except for maps and geospatial submissions. The attachment size limit for submissions is roughly 75 MB and may require interested parties to send more than one email in the event attachments exceed this limit. There is no page limit on comments. DOE requests that comments include the name(s), phone number(s), and email address(es) for the principal point(s) of contact, as well as relevant institution and/or organization affiliation (if any) and postal address. Note that there is no prohibition on the number of information submissions from an interested party, though DOE encourages interested parties making multiple submissions to include an explanation of any relationship among those submissions.

DOE will grant party status to anyone who comments in response to the notice of the preliminary list of potential NIETC designations, in the manner and by the deadline indicated above.

Only those granted party status may request rehearing of the DOE’s decision, or appeal the NIETC in court. Protect your due process rights because you don’t know now whether you may want to request rehearing, or appeal an adverse decision. You are an interested party if: you are a person or entity, State, or Indian Tribe, concerned with DOE’s exercise of its discretion to designate a geographic area as a NIETC. Becoming a party does not obligate you to any further action, it only gives you the option of taking further action if you choose.

State in your comments that you are requesting interested party status in accordance with DOE’s NIETC Guidance at Pages 41-42 to preserve your right to request rehearing or appeal a corridor designation. Include comments that may become the basis for your appeal (where DOE is not following the statute). More information about the statute in the long version of this guidance that you may download at the end of this blog.

We are urging interested people to submit comments in two phases. RIGHT NOW and BEFORE THE JUNE 24 deadline.

RIGHT NOW:
To demand public notice and engagement from DOE and set a new comment deadline at least 45 days after the conclusion of the public engagement period. Ask for direct notification by mail of each impacted landowner within the corridor, as well as public notification, including posted notices in all local newspapers servicing the area of each proposed corridor. Request public information meetings, including an online meeting option for those who cannot attend in person. Ask that DOE share all available information on each corridor it is considering, including a narrative description of its boundaries, as well as identification of all transmission line(s) currently planned or proposed for the corridor.

We cannot comment on corridor requests submitted by utilities if we cannot read the requests! We cannot make effective comment on information DOE is keeping secret! It does little good to hold a public comment period for a project that has not provided notice to impacted landowners or disseminated adequate public information.

DOE states, “Early, meaningful engagement with interested parties should reduce opposition to NIETC designation and to eventual transmission project siting and permitting within NIETCs, meaning more timely deployment of essential transmission investments.” But the DOE has not provided any notice or public information about this process, or attempted to engage impacted communities. DOE needs to walk their talk.
Also consider writing to your U.S. Senators and Representatives and asking them to intervene on your behalf to ask DOE for public notice and engagement for the Phase 2 comment period.

See this link for a form letter and help contacting your representatives.

BEFORE JUNE 24:
At the end of Phase 2, DOE will identify which potential NIETCs it is continuing to consider, including the preliminary geographic boundaries of the potential NIETCs, the preliminary assessment of present or expected transmission capacity constraints or congestion that adversely affects consumers, and the list of discretionary factors in FPA section 216(a)(4) that DOE has preliminarily identified as relevant to the potential NIETCs.

DOE invites comments from the public on those potential NIETCs, including recommendations and alternatives.

​Phase 2 provides a high level explanation of why the potential NIETCs in the list are moving forward in the NIETC designation process, and you are encouraged to provide additional information on why DOE should or should not proceed with a certain corridor.

Your comments before June 24 should focus on the underlying need within the geographic area as well as “information and recommendations” from DOE’s 13 Resource Reports and other possible topics below in order to narrow the list of potential NIETC designations. DOE also requests information on potential impacts to environmental, community, and other resources within the proposed corridor.

DOE’s 13 Resource Reports: (1) geographic boundaries; (2) water use and quality; (3) fish, wildlife, and vegetation; (4) cultural resources; (5) socioeconomics; (6) Tribal resources; (7) communities of interest; (8) geological resources; (9) soils; (10) land use, recreation, and aesthetics; (11) air quality and environmental noise; (12) alternatives; and (13) reliability and safety.

DOE requests that interested parties provide in their Phase 2 comments the following resource information: concise descriptions of any known or potential environmental and cumulative effects resulting from a potential NIETC designation, including visual, historic, cultural, economic, social, or health effects thereof.

A list of potential topics includes:

1. Width of proposed NIETC (5 miles for GBE). All properties within NIETC will have the perpetual cloud of potential eminent domain taking for new transmission. This lowers resale value.
2. Area of NIETC not the right size or in the right place for alternatives or route changes you suggest, such as routing on existing highway or railroad easements.
3. Federal authorizations needed to build across government land, including impacts to other state or federal land in the corridor.
   
4. Need for the project – Do we need new transmission, or would it be a better idea to build generation near load rather than importing electricity thousands of miles from other states? Suggest other options to supply power such as in-state generation from natural gas, biomass, waste-to-energy, nuclear, small modular nuclear, other large scale power generation in close proximity to the need. The federal government can use corridors to force new transmission on states, but cannot force new electric generation on states. Something is wrong with this scenario.
5. Diversification of electric supply.
   
6. Energy independence and security. Defense and homeland security.
   
7. National energy policy (not defined).
   
8. Are there any customers for the transmission lines proposed for the corridor?
   
9. How the corridor may enable for-profit merchant transmission that is not a public utility.
   
10. Are there any transmission projects in the corridors that have been approved by a regional transmission organization? (SPP, MISO, PJM).
    
11. Maximize use of existing rights-of-way without expanding them, including utility, railroad, highway easements. Reconductor existing lines instead of building new (new wires with increased capacity) without expanding the easement. Buried lines on existing highway or rail rights-of-way, including high-voltage direct current.
    
12. Environmental and historic sites.
    
13. Costs to consumers. Who will pay for new transmission in corridors? New transmission regionally allocated to consumers will increase electric costs for all consumers. Everyone pays to construct new regionally-planned transmission in these corridors, even if we don’t benefit.
    
14. Water use and quality, wetlands.
    
15. Fish, wildlife and vegetation impacts. Consider future vegetation management under the lines that includes the use of herbicides, weed killers or other substances toxic to humans, animals or cultivated plantings that are either sprayed on new easements from the air or by on the ground vehicles. Construction vehicles and equipment can spread undesirable, invasive vegetation along the corridor.
    
16. Cultural resources – Historic, tribal, other. Socioeconomics – impacts on property, income, quality of life, use of eminent domain.
    
17. “Communities of interest” – environmental justice, racial disparities, income disparities, energy burden.
    
18. Energy equity and justice: Grain Belt Express has already taken property and disturbed agricultural and other businesses, now the federal government is coming back for 5 more miles of property. The impacts to farms will be devastating.
    
19. Geologic – Sink holes, fault lines, abandoned mines.
    
20. Soil – erosion, loss of topsoil, loss of vegetation, drainage, compaction, introduction of rock from blasting, destruction of prime or unique farmland, protected farmland, agricultural productivity.
    
21. Land use, recreation and aesthetics – changes to land use, homes and farms, conservation easements, parks, churches, cemeteries, schools, airports, visual impacts, public health and safety.
    
22. Environmental noise and air quality – construction noise, operational noise, impacts to air quality and emissions caused by project, both during construction and while in operation. 

DOE must consider alternatives and recommendations from interested parties. Feel free to suggest as many alternatives as you want in one or more submissions.

DOE will prioritize which potential NIETCs move to Phase 3 based on the available information on geographic boundaries and permitting and preliminary review of comments.
​
DOE must review public comments, consider recommendations and alternatives suggested. 

Want to read more suggestions and tips?  Download a longer version of these guidelines with additional information, quotes you can use, and more web resources to explore.

Here's a little extra help planning your comments on the U.S. Department of Energy's preliminary Mid-Atlantic Corridor.  If you're concerned about a different corridor, such as the Midwest-Plains corridor that follows Grain Belt Express, there will be slightly different  guidance, coming soon.

The Mid-Atlantic Corridor roughly follows the path of the MidAtlantic Resiliency Link, or MARL, project that PJM ordered NextEra and FirstEnergy to build last December.  It begins at 502 Junction substation in southwestern Pennsylvania and traverses through West Virginia, Maryland, and Virginia on its way to bring coal-fired electricity from West Virginia to Northern Virginia's data centers.  It looks like this.  The lines on this map may be 200-400 feet wide.

DOE's National Interest Electric Transmission Corridor that corresponds with that project looks like this:

Each line on this map is 2 miles wide.

Here's my advice on submitting effective comments.  Make sure you have also sent your extension request and letters to elected officials for Step 1.

Quick Guide for Citizen Participation in Phase 2 Comments

DOE’s announcement of proposed corridors begins Phase 2 of its process. Phase 2 allows “information and recommendations” and comment from any interested party and you are urged to submit your comments. DOE requests information submissions in Phase 2 by 5:00 pm on June 24, 2024. Interested parties may email comments as attachments to [email protected]. You are encouraged to request DOE acknowledge your submission by return email so that you know it was received by the deadline. DOE requests comments in Microsoft Word or PDF format, except for maps and geospatial submissions. The attachment size limit for submissions is roughly 75 MB and may require interested parties to send more than one email in the event attachments exceed this limit. There is no page limit on comments. DOE requests that comments include the name(s), phone number(s), and email address(es) for the principal point(s) of contact, as well as relevant institution and/or organization affiliation (if any) and postal address. Note that there is no prohibition on the number of information submissions from an interested party, though DOE encourages interested parties making multiple submissions to include an explanation of any relationship among those submissions.

DOE will grant party status to anyone who comments in response to the notice of the preliminary list of potential NIETC designations, in the manner and by the deadline indicated above. Only those granted party status may request rehearing of the DOE’s decision, or appeal the NIETC in court. Protect your due process rights because you don’t know now whether you may want to request rehearing, or appeal an adverse decision. You are an interested party if: you are a person or entity, State, or Indian Tribe, concerned with DOE’s exercise of its discretion to designate a geographic area as a NIETC. Becoming a party does not obligate you to any further action, it only gives you the option of taking further action if you choose.

State in your comments that you are requesting interested party status in accordance with DOE’s NIETC Guidance at Pages 41-42 to preserve your right to request rehearing or appeal a corridor designation. Include comments that may become the basis for your appeal (where DOE is not following the statute). More information on the statute in the long version of this guidance that you can download at the bottom of this blog.

We are urging interested people to submit comments in two phases. RIGHT NOW and before the deadline.

RIGHT NOW:
To demand public notice and engagement from DOE and set a new comment deadline at least 45 days after the conclusion of the public engagement period. Ask for direct notification by mail of each impacted landowner within the corridor, as well as public notification, including posted notices in all local newspapers servicing the area of each proposed corridor. Request public information meetings, including an online meeting option for those who cannot attend in person. Ask that DOE share all available information on each corridor it is considering, including a narrative description of its boundaries, as well as identification of all transmission line(s) currently planned or proposed for the corridor.
We cannot comment on corridor requests submitted by utilities if we cannot read the requests! We cannot make effective comment on information DOE is keeping secret! It does little good to hold a public comment period for a project that has not provided notice to impacted landowners or disseminated adequate public information. DOE states, “Early, meaningful engagement with interested parties should reduce opposition to NIETC designation and to eventual transmission project siting and permitting within NIETCs, meaning more timely deployment of essential transmission investments.” But the DOE has not provided any notice or public information about this process, or attempted to engage impacted communities. DOE needs to walk their talk. Also consider writing to your U.S. Senators and Representatives and asking them to intervene on your behalf to ask DOE for public notice and engagement for the Phase 2 comment period.
See this link for a form letter and help contacting your representatives.

BEFORE JUNE 24:
At the end of Phase 2, DOE will identify which potential NIETCs it is continuing to consider, including the preliminary geographic boundaries of the potential NIETCs, the preliminary assessment of present or expected transmission capacity constraints or congestion that adversely affects consumers, and the list of discretionary factors in FPA section 216(a)(4) that DOE has preliminarily identified as relevant to the potential NIETCs.

DOE invites comments from the public on those potential NIETCs, including recommendations and alternatives.

Phase 2 provides a high level explanation of why the potential NIETCs in the list are moving forward in the NIETC designation process, and you are encouraged to provide additional information on why DOE should or should not proceed with a certain corridor.

Your comments before June 24 should focus on the underlying need within the geographic area as well as “information and recommendations” from DOE’s 13 Resource Reports and other possible topics below to narrow the list of potential NIETC designations. DOE also requests information on potential impacts to environmental, community, and other resources within the proposed corridor.

DOE’s 13 Resource Reports: (1) geographic boundaries; (2) water use and quality; (3) fish, wildlife, and vegetation; (4) cultural resources; (5) socioeconomics; (6) Tribal resources; (7) communities of interest; (8) geological resources; (9) soils; (10) land use,
recreation, and aesthetics; (11) air quality and environmental noise; (12) alternatives; and (13) reliability and safety.

DOE requests that interested parties provide in their Phase 2 comments the following resource information: concise descriptions of any known or potential environmental and cumulative effects resulting from a potential NIETC designation, including visual, historic, cultural, economic, social, or health effects thereof.

In addition to the above, a list of potential topics includes:

1. Expansion of existing transmission easements to add new lines. Expansion will remove all existing buildings, lighting fixtures, signs, billboards, swimming pools, decks, flag posts, sheds, barns, garages, playgrounds, fences or other structures within the expanded easement area. Existing septic systems, leach beds, and/ or wells may not be permitted within the expanded easement area. This would seriously damage host properties or make them uninhabitable.
2. Width of proposed NIETC (2 miles for MidAtlantic). All properties within the NIETC will have the perpetual cloud of potential eminent domain taking for new transmission. This lowers resale value.
3. Area of NIETC not large enough or in the right place for alternatives or route changes you suggest, such as routing on existing highway or railroad easements. Federal authorizations needed (crossing Appalachian Trail, C&O Canal), along with impacts to other federal land in the corridor such as Harpers Ferry NHP, The National Conservation Training Center, Antietam Battlefield, to name a few examples.
4. Need for the project – Do we need new transmission, or would it be a better idea to build generation near data centers instead of importing electricity from neighboring states? This new electric supply is only needed for data centers – suggest other options to supply power such as in-state generation from natural gas, biomass, waste-to-energy, nuclear, small modular nuclear, other large scale power generation in close proximity to the data center load. Building in-state gas generation is constrained by Virginia’s energy policy, which can be changed to avoid new transmission. The federal government can use corridors to force new transmission on states, but cannot force generation choices on states. Something is wrong with this scenario.
5. Diversification of electric supply.
6. Energy independence and security. Defense and homeland security.
7. National energy policy (not defined).
8. New transmission in the corridor will enhance the ability of coal-fired generators to connect additional capacity to the grid, resulting in increased emissions. Two plants slated for closure have already had their useful life extended (FirstEnergy’s Harrison and Ft. Martin). Imports constrain development of renewable generation in Northern Virginia by importing lower cost coal-fired electricity from other states.
9. Maximize use of existing rights-of-way without expanding them, including utility, railroad, highway easements. Reconductor existing lines (new wires with increased capacity) without expanding the easement. Buried lines on existing highway or rail rights-of-way, including high-voltage direct current.
10. Environmental and historic sites.
11. Costs to consumers. Are the data centers a “consumer” or a beneficiary? New transmission to serve new data centers will increase electric costs for all consumers. Everyone pays to construct new transmission in these corridors, even if we don’t benefit.
12. Water use and quality, wetlands.
13. Fish, wildlife and vegetation impacts. Consider future vegetation management under the lines that includes the use of herbicides, weed killers or other substances toxic to humans, animals or cultivated plantings that are either sprayed on new easements from the air or by on the ground vehicles. Construction vehicles and equipment can spread undesirable, invasive vegetation along the corridor
14. Cultural resources – Historic, tribal, other.
15. Socioeconomics – impacts on property, income, quality of life, use of eminent domain.
16. “Communities of interest” – environmental justice, racial disparities, income disparities, energy burden.
17. Geologic – Karst, abandoned mines.
18. Soil – erosion, loss of topsoil, loss of vegetation, drainage, compaction, introduction of rock from blasting, destruction of prime or unique farmland,
    protected farmland, agricultural productivity.
19. Land use, recreation and aesthetics – changes to land use, homes and farms, conservation easements, parks, churches, cemeteries, schools, airports, visual impacts, public health and safety.
20. Environmental noise and air quality – construction noise, operational noise, impacts to air quality and emissions caused by project (increased use of coal in WV to supply power to data centers – Mitchell, Harrison, Ft. Martin, Longview and Mt. Storm coal-fired power plants feed these corridors).
21. Alternatives – suggest alternatives to this corridor, whether it is different design, different routing, or different power source.
22. Public safety – hazards to community from weather or operational failure or terrorist attack, health hazards from electromagnetic fields and stray voltage.
23. Your interaction (or lack thereof) with company applying for corridor. Lack of notice.

DOE must consider alternatives and recommendations from interested parties. Feel free to suggest as many alternatives as you want in one or more submissions.

DOE will prioritize which potential NIETCs move to Phase 3 based on the available information on geographic boundaries and permitting and preliminary review of comments. DOE must review public comments, consider recommendations and alternatives suggested. 

Want to read more suggestions and tips?  Download a longer version of these guidelines with additional information, quotes you can use, and more web resources to explore.