Cunningham-Dooms 500 kv Rebuild

Transcription

1 Project Updates - III.d Cunningham-Dooms 500 kv Rebuild 1 of 19

2 Project Updates - III.d.i virginiaoutdoorsfoundation.org Memorandum To: VOF Committee on Energy and Infrastructure From: Brian Fuller Date: 05/12/2016 Re: Dominion Virginia Power Transmission Line Upgrade Cunningham to Dooms 03/02/2016 Dominion files the project with SCC (Case No. PUE ) 03/17/2016 VOF receives request for comment on SCC filing from DEQ 03/30/2016 VOF responds to DEQ request for comment, noting the following: o VOF easements on 25 properties within 1.5 miles of the transmission corridor o Of those 25 properties, the line physically crosses 4 properties under easement o VOF is working on 1 new proposal within 1.5 miles of the transmission corridor 04/04/2016 VOF sends a letter to all 4 property owners along the Dominion ROW notifying them of the SCC filing and VOF s response 04/14/ /02/2016 Martha Little responds to DEQ and Dominion about additional questions regarding VOF s comments (see attached correspondence) 04/26/2016 Landowners along the route (David King and Robert Carter) contact Brian Fuller voicing their opposition to the project; Mr. Carter files comments with SCC 2 of 19

3 5/12/2016 Cunningham Dooms 500kV Rebuild Project Updates - III.d.ii Cunningham-Dooms 500kV Rebuild Dominion Virginia Power is committed to meeting our obligation to provide safe and reliable service to its customers. As the demand for electricity has grown steadily, Dominion has continued to replace aging infrastructure across our service territory in particular, we are working to replace high voltage lines built and placed into service in the 1960s. One segment to be rebuilt is an existing corridor located between the Cunningham Substation in Fluvanna County and the Dooms Substation in Augusta County which passes through Albemarle County. No new right of way is needed for Dominion s proposal to rebuild this line. Project Need and Description As the demand for electricity has grown steadily, Dominion has continued to replace aging infrastructure across our service territory in particular, we are working to replace the 500 kilovolt (500kV) highvoltage lines that were placed into service in the 1960s. This line, between the Cunningham and Dooms substations, is nearing the end of its useful life and needs to be replaced with new equipment to meet current standards. Approximate total line length is 33 miles No additional right of way is need for this rebuild Typical structure description The existing 500kV structures average 106 feet tall with a range from 72 feet to 149 feet. The preliminary approximate heights of the proposed towers range from 108 feet to 174 feet with an overall average height of 134 feet over this 32 mile rebuild project. Compared to the existing structures, the increase in average height is 28 feet. View existing and proposed configurations below: Section #1 0.8 mile Preliminary engineering, as of February 8, 2016 Section #2 1.2 miles Preliminary engineering, as of February 8, 2016 Section #3 2 miles Preliminary engineering, as of February 8, 2016 Section # miles Preliminary engineering, as of February 8, 2016 Section #5 9 miles Preliminary engineering, as of 3 of 19 we do/electricity/transmission lines and projects/cunningham dooms 500kv rebuild?print=true 1/5

4 5/12/2016 Cunningham Dooms 500kV Rebuild February 8, 2016 Section #6 0.7 mile Preliminary engineering, as of February 8, 2016 Project Updates - III.d.ii Project Benefits Help strengthen the electrical grid Replace aging infrastructure Ensure reliable electric service for the customers consistent with North American Electric Reliability Corporation reliability standards Additionally, Dominion electric transmission projects provide numerous, positive economic benefits to local communities Replacing infrastructure provides an incremental increase to local property taxes Dominion employees and contractors support local businesses during construction Route Map View a basic map of the route. Project Timeline Late 2015/Early 2016 Public outreach to counties, elected officials and adjacent property owners February 2016 Informational open houses in Crozet, Waynesboro, Charlottesville Early 2016 File application with the State Corporation Commission (SCC) Summer 2017 Secure necessary permits for construction; pending SCC approval, construction scheduled to begin December 2018 Target date to energize the rebuilt transmission line SCC Approval Process The State Corporation Commission (SCC) is responsible for determining the need, route and environmental impact of transmission lines at 138kV and above in Virginia. Dominion filed an application with the SCC on March 2, Links to the two volume application are below: Volume One Volume Two Contact Us 4 of 19 we do/electricity/transmission lines and projects/cunningham dooms 500kv rebuild?print=true 2/5

5 5/12/2016 Cunningham Dooms 500kV Rebuild Contact Us Project Updates - III.d.ii Contact us if you have questions or would like more information about the project. Let us know if you would like to receive project updates via . You may also call us directly at Questions and Answers Expand All Collapse All Will Dominion require additional right of way? No, the proposed transmission line will be constructed within an existing right of way. I ve read the new structures will be, on average, about 28 feet taller. Why are the new towers taller? Aging Cor Ten steel towers will be replaced with new galvanized steel lattice towers. Use of modern materials, compliance with National Electrical Safety Code (NESC) clearance requirements, and application of good utility engineering practices require the new towers to be taller structures. Dominion's Transmission Engineering Group determines structure locations and structure types for high voltage transmission lines based on a wide variety of data and factors including, but not limited to, National Electrical Safety Code (NESC) clearance requirements, terrain, line sag between towers, voltage levels, equipment needs, route design, land use, and natural or manmade obstacles. Given the statutory preference to use existing rights of way to avoid additional costs and environmental impacts, Dominion plans to optimize the use of the existing corridor as already built between the Cunningham and Dooms substations. Will Dominion repair damage due to construction? Yes. Our easement agreements allow us access to private roads of property owners crossed by the right of way. The company, at its expense, will repair any private roads damaged by Dominion or its contractors during construction of the line or during future maintenance. In addition, we will reimburse property owners for crop damage, and repair or replace fences or gates if we damage them. Should I be concerned about Electric and Magnetic Fields? Dominion is sensitive to public concern about possible health effects from exposure to electric and magnetic fields (EMF). Dominion includes data on the levels of both electric and magnetic fields produced by proposed facilities in all applications submitted with the 5 of 19 we do/electricity/transmission lines and projects/cunningham dooms 500kv rebuild?print=true 3/5

6 5/12/2016 Cunningham Dooms 500kV Rebuild SCC. We continually monitor EMF research and speak to our customers and employees regularly to share the latest information available. Project Updates - III.d.ii The Virginia SCC, which regulates the construction and operation of electric transmission lines of 138kV and above, considers EMF in every application. Hearing Examiner s remarks from recent proceedings are below. March 23, 2009 Beaumeade NIVO (Case Number PUE ) Report of Michael D. Thomas, Hearing Examiner concludes that " electric transmission line electromagnetic fields do not represent a human health hazard. May 4, 2010 Hayes Yorktown (Case Number PUE ) Report of Deborah V. Ellenberg, Chief Hearing Examiner, states, I find that EMF has not been identified as a carcinogen for human beings despite extensive study over many years, and there is, therefore, no basis on which to prohibit the Company from authorizing appropriate uses of its right of way. August 23, 2011 Hollymead (Case Number PUE ) Report of Michael D. Thomas, Hearing Examiner, states, The proposed facilities do not represent a hazard to human health, which finding is consistent with the Virginia Department of Health s report entitled Monitoring of Ongoing Research on the Health Effects of High Voltage Transmission Lines (Final Report) dated October 31, May 1, 2015 Brambleton Mosby (Case Number PUE ) Report of Howard P. Anderson, Hearing Examiner, states, Expert panels formed by national and international scientific agencies have evaluated the scientific research related to health and power frequency EMF and provided conclusions that form the basis of guidance to governments and industries. It is the general scientific consensus of the health agencies reviewing this research that at levels associated with the operation of the proposed transmission line, or other common sources of EMF in the environment, the research does not support the conclusion that EMF causes any long term, adverse health effects. The Virginia Department of Health in its final report evaluating EMF research concluded: "Based on the review and analysis of the exhaustive literature review and other research projects completed under the EMF RAPID program, the Virginia Department of Health is of the opinion that there is no conclusive and convincing evidence that exposure to extremely low frequency EMF emanated from nearby high voltage transmission lines is causally associated with an increased incidence of cancer or other detrimental health effects in humans. Even if it is assumed that 6 of 19 we do/electricity/transmission lines and projects/cunningham dooms 500kv rebuild?print=true 4/5

7 5/12/2016 Cunningham Dooms 500kV Rebuild there is an increased risk of cancer as implied in some epidemiologic studies, the empirical relative risk appears to be fairly small in magnitude and the observed association appears to be tenuous. The studies published in the literature lack clear demonstration of a cause and effect relationship as well as a definitive dose response gradient." Project Updates - III.d.ii Additional information: National Institute of Environmental Health Sciences Electrical and Magnetic Fields Virginia Department of Health Final Report on EMF Research View Dominion's latest EMF update. How can I get involved and better understand the transmission line planning and approval process? Dominion welcomes comments and suggestions from property owners and the general public. If you have any questions, send an to powerline@dom.com and let us know if you would like for Dominion to send you project updates or invitations to future opportunities for public participation. Dominion welcomes comments and suggestions from property owners and the general public. If you have any questions, send an to powerline@dom.com and let us know if you would like for Dominion to send you project updates or invitations to future opportunities for public participation. Copyright 2016 Dominion 7 of 19 we do/electricity/transmission lines and projects/cunningham dooms 500kv rebuild?print=true 5/5

8 Galvanized Steel Proposed H Project Updates - III.d.ii Existing G PRELIMINARY ENGINEERING 8 of 19

9 December 22, 2015 VIA Ms. Amanda Mayhew Dominion Virginia Power P.O. Box Richmond, VA RE: Dominion Virginia Power s Proposed Transmission Project Dooms - Cunningham 500kV Line Rebuild Augusta, Albemarle and Fluvanna Counties Dear Ms. Mayhew: The Virginia Outdoors Foundation (VOF) is in receipt of a letter from you dated December 7, 2015, concerning the above-referenced project. VOF, an agency of the Commonwealth, was established by the General Assembly in 1966 to promote the preservation of Virginia s natural and cultural resources by encouraging private philanthropy in fulfillment of state policy. As a result of Virginia s commitment to ensure a vibrant natural environment for today and future generations, VOF owns thousands of acres managed for public access and holds more than 3,600 easements across the Commonwealth, and these easements protect in perpetuity over 750,000 acres of open-space. We thank you for the opportunity to provide additional comments regarding upgrades to the electric transmission corridor running through VOF open-space easements in the aforementioned counties. This project is located in a region of Virginia that contains a high concentration of our open-space easements. In advance of your filing with the SCC, you are requesting VOF s input on the proposed project. VOF understands that the proposed rebuild will occur within the existing ROW, but VOF requests information on the heights and materials of the proposed new towers. While the replacement may occur within the existing ROW, VOF requests additional information on whether there are existing forests or vegetation that will need to cleared, including any clearing outside of the official ROW in the safety fall zone. VOF also requests additional information on whether any of the temporary construction infrastructure (roads, bridges, etc.) will need to occur on open-space easement property. VOF holds open-space easements on 28 properties within 1.5 miles of the transmission line, a majority of which could be visually-impacted by the proposed rebuild and upgrade. Of those 28 virginiaoutdoorsfoundation.org Richmond Office 600 E. Main Street, Suite 402, Richmond, VA of 19 Page 1 of 3

10 properties, the line physically crosses 3 properties under open-space easements within Dominion s existing ROW. Should the proposal require any additional ROW through a VOF easement, Dominion will need complete a utility easement application. Staff will evaluate the request according to the specific conservation values of each easement in determining the feasibility of additional utility right of way, which determination will be transmitted to the board for final approval. Please contact VOF staff to request this application and please note that Dominion is required to obtain separate approval from the fee owner of the subject property. In considering the impact of this proposal on conservation lands, an open-space easement is a legal interest in real property that creates a relationship between the holders of the easement and the property owner. By means of the easement, VOF has an interest in specific conservation values of the property and a legal obligation to protect these values. VOF easements provide important public benefits by protecting in perpetuity significant tracts of mostly undeveloped land which may contribute to the protection of water quality, productive soils, natural heritage resources, historic resources, and scenic viewsheds. VOF easements represent over $1 billion of public investment and fulfillment of Title XI of the Virginia Constitution and other public policies to ensure conservation of natural and cultural resources. These investments in conservation and future conservation opportunities may be jeopardized if large-scale utility development impairs the protected resources and their character-defining setting. Degradation of protected resources may result in a loss of confidence in the effectiveness of conservation easements by the public. As mentioned above, the proposed project both crosses protected lands, and will be in the viewshed of many others. VOF is concerned about the potential impact that a large-scale utility development like this may have on the scenic viewsheds and pastoral settings provided by these protected properties, especially for the driving public along I-64, US Route 29 and State Route 20. As such, VOF requests that full consideration be given to the importance of these openspace properties and their extensive conservation values in the upgrading of this transmission corridor. Alternatives of less visual impact should be fully considered and modifications to siting, location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values. If the SCC certificate is issued, the permit should require implementation of all industry best practices, including, but not limited to, (1) minimal removal of vegetation through use of a clearing plan and (2) use of non-reflecting or de-glared conductors and dulled steel for towers and structures. Thank you for the notice and we look forward to working with you and Dominion in the continued planning and evolution of this project. If you have any further questions or comments, please feel free to contact me at (804) or mlittle@vofonline.org. virginiaoutdoorsfoundation.org Richmond Office 600 E. Main Street, Suite 402, Richmond, VA of 19 Page 2 of 3

11 Sincerely, Martha Little Deputy Director, VOF cc: Brian Fuller, VOF (via ) Mike Hallock-Solomon, VOF (via ) virginiaoutdoorsfoundation.org Richmond Office 600 E. Main Street, Suite 402, Richmond, VA of 19 Page 3 of 3

12 March 30, 2016 VIA Ms. Julia Welman Department of Environmental Quality (DEQ) Office of Environmental Impact Review 629 E. Main St., 6th Floor Richmond, VA RE: PUE ; DEQ #16-049S Dominion Virginia Power s Proposed Transmission Project Dooms - Cunningham 500kV Line Rebuild Augusta, Albemarle and Fluvanna Counties Dear Ms. Welman: The Virginia Outdoors Foundation (VOF) is in receipt of an from Ms. Valerie Fulcher of DEQ, dated March 17, 2016, concerning the above-referenced project. We thank you for the opportunity to provide additional comments regarding upgrades to the electric transmission corridor running through VOF open-space easements in the aforementioned counties. This project is located in a region of Virginia that contains a high concentration of our open-space easements. VOF, an agency of the Commonwealth, was established by the General Assembly in 1966 to promote the preservation of Virginia s natural and cultural resources by encouraging private philanthropy in fulfillment of state policy. As a result of Virginia s commitment to ensure a vibrant natural environment for today and future generations, VOF owns thousands of acres managed for public access and holds more than 3,600 easements across the Commonwealth, and these easements protect in perpetuity over 780,000 acres of open-space. This transmission line was constructed in the mid-1960s with COR-TEN weathering steel towers and according to Dominion, has now reached the end of its 50-year expected life span. Dominion is proposing to replace the towers with galvanized steel lattice towers that will be approximately taller than the existing towers. The proposed galvanized towers could have a significant visual impact along the corridor in this highly scenic area of Central Virginia. Dominion states that the proposed rebuild will occur within the existing ROW. While the replacement may occur within the existing ROW, VOF requests additional information on whether there are existing forests or vegetation that will need to be cleared, including any clearing outside of the official ROW in the safety fall zone. VOF also requests additional information on whether any of the temporary construction infrastructure (roads, bridges, etc.) will need to occur on open-space easement property. virginiaoutdoorsfoundation.org Richmond Office 600 E. Main Street, Suite 402, Richmond, VA of 19 Page 1 of 3

13 VOF holds open-space easements on 25 properties within 1.5 miles of the transmission line, a majority of which could be visually-impacted by the proposed rebuild and upgrade to galvanized steel lattice towers. Of those 25 properties, the line physically crosses 4 properties under openspace easements within Dominion s existing ROW. Dominion has stated that since the proposed project is the rebuild of an existing transmission line and no additional right-of-way is required, no impact to conservation easements is expected. However, should the proposal require any additional ROW through a VOF easement, Dominion will need complete a utility easement application. Staff will evaluate the request according to the specific conservation values of each easement in determining the feasibility of additional utility right of way, which determination will be transmitted to the board for final approval. Please contact VOF staff to request this application and please note that Dominion is required to obtain separate approval from the fee owner of the subject property. In considering the impact of this proposal on conservation lands, an open-space easement is a legal interest in real property that creates a relationship between the holders of the easement and the property owner. By means of the easement, VOF has an interest in specific conservation values of the property and a legal obligation to protect these values. VOF easements provide important public benefits by protecting in perpetuity significant tracts of mostly undeveloped land which may contribute to the protection of water quality, productive soils, natural heritage resources, historic resources, and scenic viewsheds. VOF easements represent over $1 billion of public investment and fulfillment of Title XI of the Virginia Constitution and other public policies to ensure conservation of natural and cultural resources. These investments in conservation and future conservation opportunities may be jeopardized if large-scale utility development impairs the protected resources and their character-defining setting. Degradation of protected resources may result in a loss of confidence in the effectiveness of conservation easements by the public. As mentioned above, the proposed project both crosses protected lands, and will be in the viewshed of many others. VOF is concerned about the potential impact that a large-scale utility development like this may have on the scenic viewsheds and pastoral settings provided by these protected properties, especially for the driving public along Interstate 64, US Route 29, US Route 250 and State Route 20. As such, VOF requests that full consideration be given to the importance of these open-space properties and their extensive conservation values in the upgrading of this transmission corridor. Specifically, VOF is concerned about the proposed galvanized steel lattice towers. Alternatives of less visual impact should be fully considered and modifications to siting, location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values. If the SCC certificate is issued, the permit should require implementation of all industry best practices, including, but not limited to (1) minimal removal of vegetation through use of a clearing plan and (2) use of nonreflecting or de-glared conductors and dulled steel for towers and structures. virginiaoutdoorsfoundation.org Richmond Office 600 E. Main Street, Suite 402, Richmond, VA of 19 Page 2 of 3

14 Thank you for the notice and we look forward to working with you and Dominion in the continued planning and evolution of this project. If you have any further questions or comments, please feel free to contact me at (804) or Sincerely, Martha Little Deputy Director, VOF cc: Amanda Mayhew, Dominion (via ) Brian Fuller, VOF (via ) Tracy Hibbitts, VOF (via ) Mike Hallock-Solomon, VOF (via ) virginiaoutdoorsfoundation.org Richmond Office 600 E. Main Street, Suite 402, Richmond, VA of 19 Page 3 of 3

15 April 4, 2016 Landowner Address Address RE: Dominion Virginia Power s Proposed Transmission Project Dooms Cunningham 500kV Line Rebuild (Across Property: VOF-0XXXX) Dear Mr. and Mrs. Landowner: The Virginia Outdoors Foundation (VOF) is currently working with the Department of Environmental Quality (DEQ) in the review of Dominion s plans to rebuild a high-voltage electrical transmission line that traverses your property. Since your property is also held in openspace easement with VOF, we wanted to provide you with a brief update of information received from DEQ and the State Corporation Commission (SCC). The proposal is requesting to rebuild the existing 500kV line alongside the existing 230kV line within the existing ROW from Dooms in Augusta County, across Albemarle County, to Cunningham in Fluvanna County. Dominion states that the proposed rebuild will occur within the existing ROW. However, Dominion is proposing to replace the existing COR-TEN weathering steel lattice towers with galvanized steel lattice towers that will be approximately 28 taller, on average, than the existing towers. The proposed galvanized steel towers could have a significant visual impact along the corridor in this highly scenic area of Central Virginia. On March 30, VOF formally commented on the SCC review of the project in a letter to DEQ. In our letter (enclosed), VOF requested that full consideration be given to the importance of openspace easement properties and their extensive conservation values in the upgrading of this transmission corridor. We will keep you updated as this project progresses. If you have any specific comments or concerns regarding this proposed rebuild project, please provide your comments to DEQ, SCC or Dominion directly. If you have any further questions regarding your open-space easement, please feel free to contact me via phone at (434) or via at bfuller@vofonline.org. Sincerely, Brian G. Fuller Assistant Director of Stewardship Central Region, Charlottesville Office Encl: VOF Letter to DEQ dated March 30, 2016 virginiaoutdoorsfoundation.org Central Region 1010 Harris Street, Suite 6, Charlottesville, VA of 19 Page 1 of 1

16 Fuller, Brian (VOF) From: Sent: To: Cc: Subject: Little, Martha (VOF) Friday, April 15, :19 PM Fuller, Brian (VOF); Glymph, Brett (VOF) Hibbitts, Harry (VOF) FW: Cunningham-Dooms 500 kv Transmission Line, PUE / DEQ #16-049S fyi From: Little, Martha (VOF) Sent: Friday, April 15, :18 PM To: 'Charlotte P McAfee (Services - 6)'; Wellman, Julia (DEQ) Cc: Amanda M Mayhew (VirginiaPower - 6); G. W. Jackson (VirginiaPower - 6) Subject: RE: Cunningham-Dooms 500 kv Transmission Line, PUE / DEQ #16-049S Julia and Charlotte, VOF would like to respond with the following: We appreciate Dominion Virginia Power s responses to the concerns outlined in our letter dated, March, regarding: PUE ; DEQ #16-049SDominion Virginia Power s Proposed Transmission Project Dooms - Cunningham 500kV Line Rebuild Augusta, Albemarle and Fluvanna Counties VOF would like to reiterate the points made in that letter and specifically the following points: VOF is concerned about the proposed galvanized steel lattice towers. Alternatives of less visual impact should be fully considered and modifications to siting, location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values. If the SCC certificate is issued, the permit should require implementation of all industry best practices, including, but not limited to (1) minimal removal of vegetation through use of a clearing plan and (2) use of non-reflecting or de-glared conductors and dulled steel for towers and structures. We appreciate Dominion Virginia Power s response to our concern regarding the removal of vegetation and have no further comments on that. However, with regard to our request for consideration of the use of low reflective visual mitigations, we would like to point out that we have worked with other utilities, specifically the Appalachian Power Company (ACP) who has implemented these visual mitigations in the construction of electric transmission lines. ACP has used a darkened or low-reflective treatment applied to the finish of galvanized steel lattice towers to reduce the visual presence of the structures in scenic areas. They have also applied a non-specular finish to reduce glare and mitigate visual impacts to the conductors. These significant and proven visual mitigations demonstrate that it is possible to make changes to the design and materials of electric transmission lines in some cases. VOF would ask that Dominion Virginia Power consider any measures that might minimize the visual impacts to the important scenic, and cultural resources of this region. VOF hopes to continue to work with Dominion Virginia Power in a collaborative way to ensure that the Commonwealth s investments in the protection of open space are not jeopardized in any way. Thank you again for the opportunity to comment. Martha Little 1 16 of 19

17 From: Charlotte P McAfee (Services - 6) [mailto:charlotte.p.mcafee@dom.com] Sent: Thursday, April 14, :45 AM To: Wellman, Julia (DEQ) Cc: Little, Martha (VOF); Amanda M Mayhew (VirginiaPower - 6); G. W. Jackson (VirginiaPower - 6) Subject: RE: Cunningham-Dooms 500 kv Transmission Line, PUE / DEQ #16-049S Julia, Thank you for providing Dominion Virginia Power (Dominion) the opportunity to respond to the Virginia Outdoors Foundation s (VOF) letter dated March 30, 2016 regarding Dominion s Dooms-Cunningham 500kV transmission line rebuild project proposed in State Corporation Commission Case No. PUE VOF raised concerns regarding vegetation removal and use of galvanized steel towers. Dominion s response to VOF s concerns is below. 1) Vegetation removal The rebuilding of this line will not require additional tree clearing outside of the existing right-ofway, which varies in width. However, as required by North American Electrical Reliability Corporation, trees that are determined to be danger trees (any tree alive or dead that could fall within ten feet of the line) will be removed. Access to structures within the right of way will include minor improvements through the use of mats or gravel. Landowners will be notified of work on their property before the construction starts. Dominion s clearing methods are described in greater detail in Section II.A.5 of the Appendix (p. 38) and Section 2.K of the DEQ Supplement (p ) filed with the Application. 2) Materials for towers and structures Dominion has proposed to use its typical transmission line materials and structures to rebuild this line. The existing steel lattice towers (brown structures) proved to be inferior and degraded greatly over time. Dominion now uses galvanized lattice towers for all 500 kv lines. The galvanized steel is used throughout the industry and has proven to be the best type of finish for lattice towers. Depending on environmental conditions, galvanized steel lattice structures take between 24 and 48 months to achieve the typical dullness that is seen on older galvanized steel structures. Using galvanized steel towers provides the greatest protection against the elements and ensures that structures can meet the year lifespan with minimal maintenance. Dominion does not believe that the additional cost and potential decrement in structural integrity posed by the use of non-reflecting or de-glared conductors and dulled steel for structures, as requested by VOF, is appropriate. Dominion appreciates the opportunity to provide comments on the VOF letter. If there are any questions on this project please feel free to contact me. Thank you, Charlotte McAfee Charlotte P. McAfee Senior Counsel, Law Department Dominion Resources Services, Inc of 19

18 120 Tredegar Street, Riverside 2 Richmond, VA Charlotte.P.McAfee@dom.com (office) (cell) From: Wellman, Julia (DEQ) [mailto:julia.wellman@deq.virginia.gov] Sent: Tuesday, April 05, :26 AM To: Charlotte P McAfee (Services - 6) Subject: FW: Cunningham-Dooms 500 kv Transmission Line Please see the attached letter from the Virginia Outdoors Foundation. Does Dominion have any comments or response to VOF regarding its concerns on the scenic viewshed and galvanized steel lattice towers? Julia Wellman Environmental Impact Review Coordinator Department of Environmental Quality 629 E Main Street Richmond, VA (804) Julia.Wellman@deq.virginia.gov **** For program updates and public notices, please subscribe to the OEIR News Feed.**** From: Little, Martha (VOF) Sent: Friday, April 01, :34 PM To: Wellman, Julia (DEQ) Cc: Hallock-Solomon, Michael (VOF); Fuller, Brian (VOF) Subject: Cunningham-Dooms 500 kv Transmission Line Julia, Please see VOF s comments on the following project attached: Document Type: SCC Application Project Sponsor: State Corporation Commission Project Title: Cunningham-Dooms 500 kv Transmission Line Rebuild Location: Albemarle, Augusta, & Fluvanna Counties Project Number: DEQ #16-049S 3 18 of 19

19 Martha Little Deputy Director, VOF 600 East Main St., Suite 402 Richmond, Virginia P CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you of 19