EAW Submission

County map showing the general location of the project;

U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries (photocopy acceptable);

Site plan showing all significant project and natural features.

6. Description

a. Provide a project summary of 50 words or less to be published in the EQB Monitor.

A new 2 circuit, 6 strand, 300 MVA, 115kv transmission line strung on tall steel towers, sited within 30 feet of many homes, routed through attractive residential neighborhoods. It would convey power from the Red Rock substation to non-existing, unplanned, industry located near the site of the old Met Center.

b. Give a complete description of the proposed project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities.

c. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries.

The purpose of the project is not clear, as NSP's senior management appears to be making decisions without communicating with the NSP engineers charged with determining the grid's needs. Participating in the official planning process of the power pool to which NSP belongs, NSP's engineers foresaw a vague need for extra power in Bloomington in the middle of 2004.

"The last area of concern is in Bloomington near the Minneapolis/St. Paul International airport along the US 494 freeway corridor. Along with the airport expansion requiring movement of NSP transmission facilities, the old Met Center property and other land in the vicinity are being opened up for high-tech industry development by the city of Bloomington. All efforts are in the planning stage, meaning that definite transmission plans cannot be determined at this time but are under study. A best guess at this time is this will require at least the rebuild of the Stockyards-Rogers Lake 115 kV line to a double circuit line, each circuit having a 300 MVA capacity."

Source: The Upper Mississippi Valley Sub Regional Planning Group (UMV-SPG) presentation to the Transmission Planning Subcommittee (TPSC) of the Mid-Continent Area Power Pool (MAPP), March, 1999.

Separately, On November 1, 1998, NSP's engineers projected the In-Service Date for these lines as May 1, 2004 (Regional Plan, 1998 through 2007, MAPP Transmission Planning Subcommittee, Form 1).

On the same day that the TSPC issued its report, November 1, 1998, NSP announced its plans to spin off its transmission power lines to a newly formed independent company. NSP emphasized that this company's shares would be traded independently from NSP's. NSP's senior management benefits if this new stock enjoys a high valuation. Is this why NSP suddenly discovered an entirely different, much more urgent, need for the transmission lines? Exactly one month after the TSPC report was issued and the new transmission company was announced, its staff, unquestionably acting upon senior management's instructions, described a previously unidentified, immediate need to supply energy to that part of the Metro adjacent to the same Prairie Island nuclear plant whose power would be diverted to Bloomington under the NSP engineers' projections.

After examining several options, NSP was unable to establish any feasible alternative to the project described here. The reconstructed double circuit 115 kV transmission line will ensure continued, reliable electricity to the communities in the southeast metro area. Today, the system is reaching its limits. By failing to meet the proposed construction timeline, the southeast metro will be at risk for more frequent power outages.

The proposed second transmission line will ensure residents and businesses in the southeast will have reliable power in the years to come [sic].

Source, Letter to Selected homeowners, David G. Callahan SR/WA, NSP Senior Right of Way Agent, Land Services, December 1, 1998.

d. Are future stages of this development including development on any outlots planned or likely to happen? __Yes __No [unknown]

If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review.

e. Is this project a subsequent stage of an earlier project? __Yes __No

If yes, briefly describe the past development, timeline and any past environmental review.

7. Project magnitude data

Total project acreage

Number of residential units: unattached attached maximum units per building

Commercial, industrial or institutional building area (gross floor space): total square feet

Indicate areas of specific uses (in square feet):

Office Manufacturing

Retail Other industrial

Warehouse Institutional

Light industrial Agricultural

Other commercial (specify)

Building height If over 2 stories, compare to heights of nearby buildings

8. Permits and approvals required. List all known local, state and federal permits, approvals and financial assistance for the project. Include modifications of any existing permits, governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure.

Unit of government Type of application Status

9. Land use. Describe current and recent past land use and development on the site and on adjacent lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines.

10. Cover types. Estimate the acreage of the site with each of the following cover types before and after development:

Before After Before After

Types 1-8 wetlands Lawn/landscaping

Wooded/forest Impervious surfaces

Brush/Grassland Other (describe)

Cropland

TOTAL

If Before and After totals are not equal, explain why:

11. Fish, wildlife and ecologically sensitive resources

a. Identify fish and wildlife resources and habitats on or near the site and describe how they would be affected by the project. Describe any measures to be taken to minimize or avoid impacts.

The construction would endanger numerous species including the rare Blanding Turtle.

b. Are any state-listed (endangered, threatened or special concern) species, rare plant communities or other sensitive ecological resources such as native prairie habitat, colonial waterbird nesting colonies or regionally rare plant communities on or near the site? 4Yes No

If yes, describe the resource and how it would be affected by the project. Indicate if a site survey of the resources has been conducted and describe the results. If the DNR Natural Heritage and Nongame Research program has been contacted give the correspondence reference number: . Describe measures to minimize or avoid adverse impacts.

Forty five species lie under the current wires in Sunfish Lake. These include five species of pine, many native natural fauna, wild apple, butternut (which is currently on the “threatened” list in Minnesota), three species of oak, twelve species of conifers, and thirty-three species of deciduous trees. In addition, there are numerous grasses, forbes, mosses, wildflowers, and gardens of planted flowers, and bulbs.

The size of the right-of-way is much larger than the size of the study area used to gather this data. Along with this area there will be many more plants affected by any construction or destructive operations in the entire right-of-way. Included in this group will be many other trees and shrubs along the edge of the right-of-way that can suffer serious injuries due to root damage from machinery and even broken limbs and or collision injuries.

12. Physical impacts on water resources. Will the project involve the physical or hydrologic alteration — dredging, filling, stream diversion, outfall structure, diking, and impoundment — of any surface waters such as a lake, pond, wetland, stream or drainage ditch? __Yes __No

If yes, identify water resource affected and give the DNR Protected Waters Inventory number(s) if the water resources affected are on the PWI: . Describe alternatives considered and proposed mitigation measures to minimize impacts.

13. Water use. Will the project involve installation or abandonment of any water wells, connection to or changes in any public water supply or appropriation of any ground or surface water (including dewatering)? __Yes __No

If yes, as applicable, give location and purpose of any new wells; public supply affected, changes to be made, and water quantities to be used; the source, duration, quantity and purpose of any appropriations; and unique well numbers and DNR appropriation permit numbers, if known. Identify any existing and new wells on the site map. If there are no wells known on site, explain methodology used to determine.

14. Water-related land use management district. Does any part of the project involve a shoreland zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? 4Yes __No

If yes, identify the district and discuss project compatibility with district land use restrictions.

The proposed line will cross the shoreland zoning district of Sunfish Lake. The zoning restrictions in this district were mandated in part by higher levels of State government.

15. Water surface use. Will the project change the number or type of watercraft on any water body? __Yes __No

If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses.

16. Erosion and sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved:

acres ; cubic yards . Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control measures to be used during and after project construction.

In Sunfish Lake, the sites of some of the proposed towers are steeply sloped down to an environmentally fragile lake. The inevitable runoff from the construction will damage the lake's ecology.

17. Water quality: surface water runoff

a. Compare the quantity and quality of site runoff before and after the project. Describe permanent controls to manage or treat runoff. Describe any stormwater pollution prevention plans.

b. Identify routes and receiving water bodies for runoff from the site; include major downstream water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters.

18. Water quality: wastewaters

a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater produced or treated at the site.

b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies, and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems.

c. If wastes will be discharged into a publicly owned treatment facility, identify the facility, describe any pretreatment provisions and discuss the facility's ability to handle the volume and composition of wastes, identifying any improvements necessary.

d. If the project requires disposal of liquid animal manure, describe disposal technique and location and discuss capacity to handle the volume and composition of manure. Identify any improvements necessary. Describe any required setbacks for land disposal systems.

19. Geologic hazards and soil conditions

a. Approximate depth (in feet) to ground water: minimum average

to bedrock: minimum average

Describe any of the following geologic site hazards to ground water and also identify them on the site map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards.

b. Describe the soils on the site, giving NRCS (SCS) classifications, if known. Discuss soil granularity and potential for groundwater contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination.

20. Solid wastes, hazardous wastes, storage tanks

a. Describe types, amounts and compositions of solid or hazardous wastes, including solid animal manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments.

b. Identify any toxic or hazardous materials to be used or present at the site and identify measures to be used to prevent them from contaminating groundwater. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission.

c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans.

21. Traffic. Parking spaces added . Existing spaces (if project involves expansion) . Estimated total average

daily traffic generated . Estimated maximum peak hour traffic generated (if known) and time of occurrence

. Provide an estimate of the impact on traffic congestion on affected roads and describe any traffic improvements necessary. If the project is within the Twin Cities metropolitan area, discuss its impact on the regional transportation system.

22. Vehicle-related air emissions. Estimate the effect of the project's traffic generation on air quality, including carbon monoxide levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts. Note: If the project involves 500 or more parking spaces, consult EAW Guidelines about whether a detailed air quality analysis is needed.

23. Stationary source air emissions. Describe the type, sources, quantities and compositions of any emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any hazardous air pollutants (consult EAW Guidelines for a listing) and any greenhouse gases (such as carbon dioxide, methane, nitrous oxide) and ozone-depleting chemicals (chloro-fluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality.

24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during operation? 4Yes __No

If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.)

Obviously, heavy equipment will be brought in to facilitate the removal of the present poles and the insertion of the new poles. This equipment will inevitably destroy significant amounts of the local environment.

25. Nearby resources. Are any of the following resources on or in proximity to the site?

Archaeological, historical or architectural resources? __Yes __No

Prime or unique farmlands or land within an agricultural preserve? 4Yes __No

Designated parks, recreation areas or trails? 4Yes __No

Scenic views and vistas? 4Yes __No

Other unique resources? __Yes __No

If yes, describe the resource and identify any project-related impacts on the resource. Describe any measures to minimize or avoid adverse impacts.

The proposed line runs along the southern boundary of the Dodge Nature Center's Lily Preserve, a nature preserve with designated trails and a commitment to preserving nature in its pristine state. It also crosses Sunfish Lake, a unique body that, with the exception of the power lines, has been preserved as near as possible in its original, natural state.

26. Visual impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? 4Yes __No

If yes, explain.

Aesthetically, the lines and towers are totally inappropriate. They run through residential communities, many of which prohibit overhead power lines.

The present wood towers, which blend to a certain extent into the surrounding foliage, would be replaced by tall steel towers. (See attached sample photographs).

27. Compatibility with plans and land use regulations. Is the project subject to an adopted local comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency?

4Yes __No. If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain.

The proposed towers are inconsistent with existing local zoning regulations regarding the building of structures near water (Sunfish Lake), and building structures greater than 50' tall (Mendota Heights). They are also inconsistent with the area's Comprehensive Plan, and with the requirement in many of the impacted communities that overhead wires should be buried. Since no community will willingly waive the rules, the plan can only be to use the State authority to impose the new power line, ignoring long standing local and regional planning efforts as expressed in zoning laws and adopted plans.

28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? 4Yes __No. If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.)

From time to time, the new lines will need to be serviced. NSP will enforce its right to bring in heavy equipment to conduct repairs and replacements. Occasionally, the towers will need to be replaced. The lines will break, creating a deadly hazard to the communities' children and adults and requiring yet more heavy equipment that will enter woods and forests, thereby destroying the local environment.

29. Cumulative impacts. Minnesota Rule part 4410.1700, subpart 7, item B requires that the RGU consider the "cumulative potential effects of related or anticipated future projects" when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative impacts. Describe the nature of the cumulative impacts and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to cumulative impacts (or discuss each cumulative impact under appropriate item(s) elsewhere on this form).

Very few transmission lines have been built for 30 years. There is, therefore, a pent up requirement for transmission facilities. Accordingly, this project and the Loon Lake project being simultaneously proposed at this time are two of the 35 transmission projects planned by MAPP for Minnesota in the next few years. (See attachment). These projects will impact 21 State Senate districts and 25 State House districts. The controversial Chisago project was the first new line under the program and this is the one of the very first under 200 kV. This line is therefore a bellwether for how the State will handle the placement of transmission power lines.

30. Other potential environmental impacts. If the project may cause any adverse environmental impacts not addressed by items 1 to 28, identify and discuss them here, along with any proposed mitigation

I. Power lines emit Electro Magnetic Fields (EMF). There are legitimate health concerns regarding EMF and disease

a. The National Institute of Health, which articulates official government policies on health matters has concluded after its 5 year, multi-million dollar "EMFRapid" review that EMF is a "possible human carcinogen."

b. The National Academy of Sciences, after a thorough review of the literature, concludes that the associations between EMF and cancer "have been shown to be statistically reliable and robust."

c. Reputable refereed scientific journals have found links between EMF and other diseases. For example, a study in the January, 1999, edition of The American Journal of Epidemiology has found that "magnetic field exposure was associated with increased risk of death from arrhythmia-related conditions and acute myocardial infarction."

d. EMF's biological activity is demonstrated by its wide acceptance as a treatment to promote bone growth.

e. United Kingdom, Norway, Sweden, Urban Spain, Australia prohibit transmission lines near residences.

f. The World Health Organization (WHO) has begun a 5-year project to address EMF's impacts.

g. This line passes within 30 feet of many homes. We believe that this is substantially closer to residences than any other new transmission line in the United States. When lines must be sited near residences, they are virtually always 300 or more feet distant.

II. Power lines reduce property values when they run close to residences.

III. Power lines are inherently unattractive and aesthetically unappealing.

IV. It is a stated planning principle in Minnesota that industry should be separated from residential neighborhoods. Power lines are an industrial project. This power line's purpose is to supply industry. Accordingly, this line violates Minnesota's planning principles.

V. Play It Safe, Transmission Towers can Kill You. Power lines are dangerous. An Iowa power company provided this warning to its customers to induce them to keep their children away from power lines. This demonstrates that these towers are dangerous to children. Is it not ridiculous for the same power companies who warn children away from power lines to insist on placing them immediately adjacent to the very backyards and playgrounds where children spend most of their time?

This warning was distributed by Iowa's Hawthorne Power Company to its customers in May, 1999. It says that "Transmission Towers have enough electricity to KILL YOU -- stay away!"

VI. Possible mitigating techniques

a. Placing the line in an alternate route that minimizes the line's impact upon residences. (Such a line is suggested in an attachment to this submission.)

b. Burying the line.

c. Increasing the capacity of other existing lines that do not cut through residential neighborhoods thereby eliminating the need for the lines.

d. Encourage high tech industry that consumes significant electric power to locate in areas served by transmission lines with excess capacity rather than in Bloomington, which apparently may suffer an energy shortfall because of the new industry.

31. Summary of issues. Do not complete this section if the EAW is being done for EIS scoping; instead, address relevant issues in the draft Scoping Decision document, which must accompany the EAW. List any impacts and issues identified above that may require further investigation before the project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions.

Planning for Transmission Lines

1. MAPP's technical conclusions developed in coordination with NSP are likely to be more accurate than subsequent NSP assertions presented to the affected public or even to official bodies during the course of hearings as it defends its plans. Therefore, it is very significant that, using NSP data, MAPP has characterized this line as a "New" line, as opposed to a reconductoring, a rebuilding, or a conversion of an existing line. MAPP has determined that the In-Service date for this line is May 1, 2004. (TPSC Regional Plan, Form 1). Separately, MAPP has stated that the lead time for transmission projects below 230 kV is about 2 years. (Ibid, section 6.2.2, page 74.) This suggests that planning for this project should begin in the middle of 2002. Why has planning begun in 1999? Why is construction scheduled for Fall, 2000. Why does not MAPP know about the new line? Why is NSP's need for the line as stated by its land acquisition specialists so different from the need articulated by its planning engineers.

2. This new line is one of the first of some 35 transmission lines that are to be built in Minnesota in the next few years. (See the attachment). There have been very few lines built in the last 30 years. Accordingly, there exist very few precedents to guide policymakers in determining the standards that should be applied in determining whether the lines are to be approved. The PUC has informally suggested that this issue should be studied. The Met Council conceded that it has given no thought to how transmission power lines fit with its plans for the Metropolitan area. The legislature has just authorized the EQB to conduct Generic Environmental Impact studies. A suitable topic for the "GEIS" is the process though which transmission power lines are sited. Is it appropriate to proceed with this line, given that it is likely that the whole issue of the placement of transmission lines may be reviewed by the EQB?

3. According to the MAPP TPSC official records, the only purpose of the new line is to supply potential new industry in Bloomington. No other purpose has been advanced by NSP in recorded MAPP proceedings. NSP's land acquisition specialists provided the only other explanation. At this time, there are no specific plans to establish such new industry, and there is a meaningful likelihood that it will never be established. Why then are we proceeding with the new line in the absence of a demonstrated need and before authorities have an opportunity to consider solutions to the potential Bloomington energy shortfall other than those that damage distant residential neighborhoods?

Transmission Lines and Health

4. Transmission lines emit EMF. According to the conclusions of a 1998 major review conducted by one of the two most senior US Government health authorities, EMF is a "possible human carcinogen" (National Institute of Health). According to a 1997 major review conducted by the other senior authority (The National Academy of Science), the relationship between EMF and cancer is "statistically significant and robust."

Nevertheless, NSP claims that "Many studies have been performed over the past 20 years to identify any adverse health effects due to power lines. The cumulative result of these studies has failed to conclude that there are harmful health effects from power lines. [Letter to selected homeowners, David G. Callahan SR/WA, NSP Senior Right of Way Agent, Land Services, December 1, 1998.] This is consistent with NSP's other statements on the subject. Note that NSP carefully avoids asserting that there is no EMF health problem or even that it believes that there is no problem. The company is probably concerned that it might be wrong. It is therefore attempting to avoid assuming legal exposure to suits filed by homeowners injured by EMF because they live adjacent to the lines. Given the above-cited recent evidence on EMF hazards and NSP's attempt to protect itself from EMF-related claims, is it appropriate for Minnesota to be the only state in the nation still allowing the construction of new transmission lines within 100 feet of human residences? Is it significant that many industrialized nations do not permit the construction of transmission lines in residential neighborhoods?

Location of the Red Rock-Rogers Lake Line

5. One terminus for the new line, Red Rock, is supplied in substantial portion by power generated at the nuclear facility at Prairie Island. Why are we increasing our dependency upon the nuclear facility when, according to NSP, it may have to be closed down within a few years because of an inability to permanently store its nuclear waste. Would it not be better to more heavily rely upon conventional sources of power?

6. Wilson is located just south of Route 494. The Stockyards terminal for the transmission line is itself just north of 494. The line itself is adjacent to 494 in Inver Grove Heights. Much of the land immediately south of 494 between Wilson and Inver Grove Heights is either vacant or industrial. It would be possible to reroute the line from Wilson to Inver Grove Heights so that no residences would be within 300 feet of the line. The land is already cleared. Compared to the proposed line, few trees, lakes, or animal habitat would be impacted if the lines were located along 494. Why not route the proposed line along the land adjacent to 494?

Cost Allocation

8. Recent academic studies prove the obvious: transmission power lines hurt property values. Many, if not all of these studies largely addressed houses 300 or more feet distant from the line, (largely because there are extremely few examples of power lines that lie closer than 300 feet to homes). The financial impact on homes closer than 300 feet is surely going to be greater than that measured by the studies. This new line is intended to support high tech industry in Bloomington. In effect, NSP is asking residential property owners in the East Metro to suffer a substantial loss in net worth so that new industry located in the South Metro can enjoy relatively low cost electricity, thereby enhancing its net worth. Is it appropriate to support a policy that forcibly transfers wealth from existing residential homes to yet unidentified new industry?

9. A technological solution would be to bury the new lines. NSP maintains that the cost of burying the lines should be borne by the owners of the adjacent property. According to NSP's own statements, the line benefits only potential new industry in Bloomington. Is it appropriate to expect the adjacent property owners to finance the costs of ameliorating the damage to their property caused by a program designed to benefit as yet unidentified owners of industry located in other, distant communities? Why should not the industries that will benefit from the new lines pay to minimize the damage the lines impose on others?

RGU CERTIFICATION. The Environmental Quality Board will only accept SIGNED Environmental Assessment Worksheets for public notice in the EQB Monitor.

I hereby certify that:

The information contained in this document is accurate and complete to the best of my knowledge.

The EAW describes the complete project; there are no other projects, stages or components other than those described in this document, which are related to the project as connected actions or phased actions, as defined at Minnesota Rules, parts 4410.0200, subparts 9b and 60, respectively.

Copies of this EAW are being sent to the entire EQB distribution list.

Signature Date

Title

Environmental Assessment Worksheet was prepared by the staff of the Environmental Quality Board at Minnesota Planning. For additional information, worksheets or for EAW Guidelines, contact: Environmental Quality Board, 658 Cedar St., St. Paul, MN 55155, 651-296-8253, or www.mnplan.state.mn.us