December 17, VIA

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Miles Morton
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1 December 17, 2015 VIA Ms. Janine Howard Department of Environmental Quality Office of Environmental Impact Review 629 E. Main St., 6th Floor Richmond, VA RE: PUE Dominion Virginia Power s Proposed Transmission Project Remington Gordonsville 230kV Line Rebuild Albemarle, Orange and Culpeper Counties Dear Ms. Howard: The Virginia Outdoors Foundation (VOF) is in receipt of an from Ms. Valerie Fulcher of DEQ, dated December 2, 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. VOF has been working very closely with Greg Baka and others from Dominion on this proposal since March This project is located in a region of Virginia that contains a high concentration of our open-space easements, including some co-held with the Virginia Department of Historic Resources. The project has gone through several variations, including potential alternatives that would construct a new line west to a new substation at Pratts in Madison County. However, currently, the proposal is requesting to rebuild the existing line within the existing ROW from Remington to Gordonsville. Dominion would prefer to have a 100 ROW along the entire corridor; however, several properties, including many under open-space easement, only have a 70 ROW. Page 1 of 4

2 While Dominion can accomplish this rebuild within the 70 ROW, it will require a greater number of towers. Richmond Office 600 E. Main Street, Suite 402, Richmond, VA Currently, a majority of the existing line is comprised of wooden H-frame towers that are approximately 50 tall on average. The proposed towers would be made of core-ten weathering steel that are approximately 103 tall on average. Although Dominion intends to upgrade the line within its existing ROW, the height of the new towers may result in a visual impact on the specific open-space easement properties that the transmission line crosses, as well as on other conserved lands within the viewshed of the line. VOF holds open-space easements on 87 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 87 properties, the line physically crosses 26 properties under open-space easements within Dominion s existing ROW. Furthermore, VOF is currently working on 2 additional new openspace easement proposals within 1.5 miles of the transmission corridor. On the 26 properties crossed by this transmission line, 14 will require additional ROW to accomplish Dominion s preferred goal of establishing a 100 ROW along the entire corridor to achieve a one-to-one tower replacement, as opposed to a greater than one-to-one tower replacement that would be required where the ROW is 70 wide. Request for additional ROW through a VOF easement will require that Dominion complete the 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 US Route 15. As such, VOF Page 2 of 4

3 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. Alternatives Richmond Office 600 E. Main Street, Suite 402, Richmond, VA 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. 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. Sincerely, Martha Little Deputy Director, VOF cc: Greg Baka, Dominion (via ) Elizabeth Tune, VDHR (via ) Martha Little, VOF (via ) Brian Fuller, VOF (via ) Mike Hallock-Solomon, VOF (via ) Page 3 of 4

4 Richmond Office 600 E. Main Street, Suite 402, Richmond, VA Page 4 of 4

VIA Email Ms. Charlotte McAfee Senior Counsel, Law Department Dominion Resources Services, Inc.

5 VIA Ms. Charlotte McAfee Senior Counsel, Law Department Dominion Resources Services, Inc. 120 Tredegar Street, Riverside 2 Richmond, VA July 21, 2016 RE: Dominion s Remington-Gordonsville Electric Transmission Project Dear Ms. McAfee: We appreciate the meeting on July 20, 2016 where you and the other Dominion Electric Transmission staff provided us with an overview of the current status of the Remington-Gordonsville Electric Transmission Project. VOF previously provided comments on the proposed project to build steel pole monopole designed structures at an average height of 103 feet. Our comments in our letter filed during the Environmental Impact review on December 17, 2015 outlined VOF s concerns regarding the potential impacts to VOF open space lands and their viewsheds. We had asked that you consider modifications to siting, location, materials and height in the design of the transmission line to minimize impacts to the public values protected by open space properties. At our meeting on July 20, 2016, you stated that in response to community and agency concerns, Dominion filed rebuttal testimony with the SCC on July 12, 2016 to provide some flexibility in the height of the proposed structures. In your rebuttal testimony, you are offering to construct double circuit H-frame structures made of COR-TEN weathering steel with an average height of approximately 85 feet and within a right of way of 140 feet if certain conditions can be met. These conditions include (1) consent by all affected property owners, (2) agency consent where applicable (including VOF), (3) grant of easements for the 40 feet beyond the 100 feet needed for the proposed Project without additional compensation from the company, and (4) uninterrupted line distance of approximately three miles. In addition, we understand that there are several VOF open space easements where the existing right of way is 70 feet, and that in order to maintain a one-for-one replacement of structures, Dominion would require a 100 foot right of way. To accommodate the shorter towers, new right of way on VOF easements for the properties with an existing 70 foot right of way would be a total of an additional 70 feet. For the properties that currently have a 100 foot right of way, the additional right of way would be 40 feet. You have stated that there will be no structures or improvements in the additional right of way, but there may be some vegetation clearing. We appreciate the opportunity to consider the proposed changes identified in Dominion s rebuttal testimony and Dominion s efforts to be responsive to concerns of the landowners and the Central Region 1010 Harris Street, Suite 6, Charlottesville, VA Page 1 of 2

6 agencies. VOF is willing to consider requests from landowners for additional right of way and an encroachment into the VOF easement for the shorter towers if VOF can determine that the conservation values of the properties will not be adversely impacted. As Mr. McGuire mentioned at the meeting yesterday, there is precedent for this action by the VOF Board in a previous request. I am attaching the resolution adopted by the Board of Trustees on October 7, 2008, where the Board approved additional right of way for the former Pearl Property in Rappahannock County (RAP-00721) to accommodate shorter towers in the Meadowbrook-Loudoun transmission line. In addition, the Board granted the authority for staff to determine on a case-by-case basis whether such a grant of additional right of way to Dominion would be permissible under easements for other landowners that requested the shorter towers. In this current case, staff will similarly evaluate the requests from landowners according to the specific conservation values of each easement in determining the feasibility of additional utility right of way. The staff determination will be transmitted to the Board for final approval. Please also note that Dominion will be required to obtain separate approval from the fee owner of each subject property. We look forward to working with you on coordinating with landowners to determine if the shorter H-frame towers can be an option for the VOF easement landowners along the transmission line route. If you have any further questions or comments, please feel free to contact me at (804) or mlittle@vofonline.org. Sincerely, Martha Little Deputy Director, VOF encl: VOF Board of Trustees Resolution cc: Brett Glymph, VOF (via ) Greg Baka, Dominion (via ) Bobby McGuire, Dominion (via ) Rusty Meadows, Dominion (via ) Elizabeth Tune, VDHR (via ) Richmond Office Main Street Centre, 600 E. Main St., Suite 402, Richmond, VA Page 2 of 2

Cunningham-Dooms 500 kv Rebuild

Project Updates - III.d Cunningham-Dooms 500 kv Rebuild 1 of 19 Project Updates - III.d.i virginiaoutdoorsfoundation.org Memorandum To: VOF Committee on Energy and Infrastructure From: Brian Fuller Date: