ML19343B842
| ML19343B842 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 12/18/1980 |
| From: | Schlicht F HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML19343B832 | List: |
| References | |
| NUDOCS 8012300702 | |
| Download: ML19343B842 (28) | |
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DIRECT TESTIMONY OF DR. FRANK G. SCHLICHT ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY RE: MARRACK CONTENTION 2(C)
(TRANSMISSION LINES / WATERFOWL) l 8 0123 Oc TOS
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1 Q. Please state your name and positionc.
2 A. My name is Frank G. Schlicht. I am Principal 3 Scientist in the Environmental Protection Department 4 of Houston Lighting & Power Company (HL&P).
5 g. What is the purpose of this testimony?
6 A. The purpose of this testimony is to respond 7 to Marrack Contention 2(c), which states in its 8 original text:
9 Neither the FES nor the FSFES addresses the impact upon migratory waterfowl along 10 the transmission routes beyond the plant site, nor considers that this impact could 11 be minimized by constructing the power lines to follow the Brazos River to the 12 south of the site, then east and then north to the O'Brien substation.
I 13 This contention was further refined in the ASLB order 14 of November 13, 1980, in which the Board stated:
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[W]e request that Staff and Applicant, 16 and Dr. Marrack, if he so desires, present evidence at the forthcoming hearing analyzing 17 (a) the impact upon migratory waterfowl along the two transmission routes (lA and 18 2C) proposed by the Applicant and concurred in by the Staff, and (b) whether the impact yg upon migratory waterfowl could be minimized by constructing the power lines to follow the Brazos River to the south of the site, 20 then east and then north to the O'Brien substation.
21 Accordingly, I will respond to the matters in contention, 22 as restated by the Board.
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l 1 Q. Aside from your qualification as stated in 2 your testimony on the cooling lake contentions, do -
3 you have any particular experience in regard to this I
l 4 contention?
5 A. I am responsible for all ecological monitoring 6 and research conducted by HL&P. Thus, any particular
- 7 ecological problems that arise on HL&P's system are 8 brought to my attention for resolution. As I note 9 later in this testimony, I thus have the practical 10 experience of having monitored the hundreds of miles 11 f transmission line on HL&P's system, a great deal of l
l 12 which is located in areas that are heavily populated 13 by waterfowl. Furthermore, I have been involved in 14 all the environmental analyses of our proposed trans-mission routes, and in this capacity I maintain a 15
"" ## I" * ' * *#" "#* #*9"# "9 #
16 collisions with transmission lines.
7 g Q. The contention broadly concerns the " impact" of Certain transmission lines upon migratory waterfowl.
What does the word " impact" mean within the context of this contention?
21 A. Based upon the concerns expressed by Dr. Marrack 22 in seeking the admission of this contention and by 23 the ASLB in admitting it, I understand the word 24 l
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1 " impact" to be limited to the issue of direct physical ,
2 collisions of waterfowl with the transmission lines, ;
3 resulting in their death or injury. I do not under- i 4 stand the word " impact" to refer to indirect effects, 5 such as the possible elimination of feeding areas or 6 disruption of nesting or roosting grounds. No one, 7 so far as i know, has suggested that the lines pose 8 any problems, whatsoever, from such indirect effects, l 9 and I certainly concur that they will not. I know of 10 no unique feeding, nesting, or roosting areas along 11 either route. Furtl[ermore, since land under the 12 lines will not be taken out of agricultural production, 13 except by the transmission tower pads, no significant 14 loss of feeding area will occur.
15 Q. For the record, what is a " migratory waterfowl"?
16 A. " Migratory waterfowl" are commonly understood g to include members of the family Anatidae--species suc as an , w u s, geese, and swans. Federal 18 g
law generally follows this classification. (Ref. 1).
Q. Briefly describe the transmission lines in question.
A. Both are 345 kv lines. Line 2C is about 22 28.5 miles long, running north about five miles from ACNGS, then generally eastward to the O'Brien substation.
.. . . , - - - - . . . - . , . . . ~ . . -.
1 Line 1A is about 36.2 miles long and runs generally 2 southeasterly from the plant to the Parish substation.
3 Tower height along both routes will generally not 4 exceed 135 feet. For more detailed descriptions of 5 the lines and their routes, please refer to ER 3.9 i 6 and ER S.3.9.
7 Q. Generally speaking, are these lines typical a or atypical of other HL&P lines?
9 A. HL&P has more than 390 miles of 345 kv 10 transmission lines, and about 220 miles of these 11 lines run across the open coastal plains, as these 12 will. When completed, therefore, these lines will 13 represent only a small percentage of HL&P's total i
14 transmission system over very similar terrain and 15 with quite similar environmental characteristics. I 16 regard these lines as quite typical for the HL&P
, 3 system.
o Q. During the decade that you have served as
! 18 nC pal Mendst of de Ensonmental Protecdon 19 epa en , y any wateded 20 deaths, whatsoever, resulting from collisions with HL&P power lines?
A. During this period I have never received a 23 report of waterfowl deaths due to collision with any 1
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1 of our transmission lines. Moreover, our 345 kv 2 system is inspected annually, typically in the early -
3 part of the year, and these inspections have never 4 indicated problems due to waterfowl collisions.
5 During the past four years there have been four 6 reports of dead " heron-type" birds observed during 7 these system inspections. The only person I know who 8 claims to have seen a waterfowl collision is Dr. Marrack.
9 Q. You testify that you have received no 10 reports of bird deaths due to collisions. Does this 11 testimony specifically cover any areas that might be 12 regarded as posing unusual risk due to bird concentrations 13 or other factors?
14 A. Yes. For example, HL&P leased lands at the 15 W. A. Parish Generating Station to rice farmers for about fifteen years. These rice fields were situated 16 to within one-fourth mile of Smithers Lake, a 2,400 17 a re lin9 pond owned by HL&P. Smithers Lake has 18 g
historically been utilized for feeding and roosting by migratory waterfowl. When rice fields were also 0
on the property, waterfowl freely traded back and forth between the lake and fields. There are no 22 known reports of waterfowl collisions with any of the facilities at this generating station.
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- 1 Another good example comes from the ongoing l
- 2 research projecta at two of HL&P's power plants which -
l 3 are situated on the Galveston Bay system. These 4 projects have been conducted by personnel and graduate 5 students of the Department of Wildlife and Fisheries 6 Sciences at Texas A&M University and Southwest Research l 7 Institute. The laboratory facilities at one of these 8 power plants are adjacent to the discharge canal, the 9 opposite side of which is paralleled by a 345 kv 10 transmission line. This area of the canal frequently ll 11 has ducks on it during the winter. During the many 12 thousands of man-hours spent in the field by personnel l 13 associated with these projects, they have never l
l reported a bird collision with these transmission 74 lines.
la.
Q. Have you ever personally observed a waterfowl 16 I
collision with an HL&P line?
l 17 A. In my capacities with HL&P, I have spent many hours in the field, some of which have been spent along or in close proximity to our transmission system, much of which is near water and/or cultivated fields utilized by waterfowl. I have never seen a bird collide with any of our lines, nor have I ever 23 l found a dead bird of any kind along the rights-of-way l 24
) that I have visited.
1 Q. Have hunters ever reported such a collision?
2 A. Waterfowl hunting is a major type of hunting -
3 activity in the immediate Houston vicinity. Hunters 4 come from all over the United States to enjoy the 5 excellent hunting in the area and have been doing so 6 for many years. With the degree of hunting in the 7 area and in view of the fact that HL&P has transmission 8 lines in some of the areas hunted, it would seem 9 reasonable to expect reports from the hunters or the 10 Professional guides if waterfowl collisions with 31 these lines were a common occurrence. EL&P has no 12 record of having ever received a report or claim of l 13 s natue.
g Q. What do you conclude from this lack of reports of waterfowl collisions?
Is_
A. I conclude that EL&P has never had~a significant problem with waterfowl collisions with its transmission system, and I expect no such problems from the ACNGS lines.
19 Q. Is this conclusion based strictly on actual experience?
21 A. No. In addition to considering the company's 22 actual experience--or more correctly, nonexperience--
23 with waterfowl collisions, I have also considered the 24 scientific literature in reaching my conclusion.
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l 1 Please summarize briefly what you have Q.
2 learned from the literature.
3 A. Until very recently, the literature on 4 waterfowl collisions was very scant. Now that the 5 subject is being studied more intersively, however, 6 it is clear that waterfowl collisions with transmission 7 lines are a very insignificant matter. The literature, 8 in short, bears out nrAP's actual experience.
9 Q. Please elaborate on your own literature l 10 searches.
1 i 11 A. In 1973, the NRC requested HL&P to quantify 12 expected waterfowl losses due to collisions with the 13 transmission line segment proposed to cross the l
- 14 cooling lake. A concerted effort was made to locate 15 literature relevant to the issue, but very little was 16 found in the literature addressing waterfowl collisions I
77 with transmission lines and towers. This is borne out by the fact that only two of the papers cited by 18 Dr. Marrack in support of his contention are dated 19 20 Prior to 1973.
Q. Have you examined those papers?
21
! A. Yes. Both report small numbers of waterfowl l 22 1
deaths from collisions with power lines, but both are 23 useless for predicting losses at other locations.
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1 Scott, et al, (1972) (Ref. 2) reported only 2 fifteen waterfowl deaths out of a total of 1,285 bird 3 casualties recorded at Dungeness over a six-year 4 period. The power lines in that study actually ran i 5 through a bird reserve, and fewer than three waterfowl 6 a year, on the average, were found to have died from Power line collisions. This consitutues about one 7
a percent of the total bird losses. This paper does 9 not, however, present data on the total number of o
10 " birds using the area during the study period, and, 11 therefore, it is useless for predicting losses at 12 other locations.
13 Cornwell and Hochbaum (1971) (Ref. 3) 14 reported on waterfowl collisions with wires. They 15 Personally observed one collision with a barbed-wire 16 fence and one with a transmission line. They also l
cited two other reported collisions, one with a 7
g barbed-wire fence and one with a telephone line.
This anecdotal paper, too, is of no value in estimating 19 i
vaterfowl losses due to transmission line collisions, l 20 as no data are presented on the number of birds using l
the area or flying in the vicinity.
l 22 Two other papers brought to the attention of HL&P at the time of the initial study were those l
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1 by Stoddard (1962) (Ref 4) and Stoddard and Norris (1967) 2 (Ref 5). These two paperc were, and still are, also -
3 of little value in assessing waterfowl mortality due !
! 4 to transmission lines and towers. They deal with 5 mortalities due to striking a lighted TV tower and 6 its guy-wires. This research found "much evidence to 7 indicate that guy-wires are very deadly." Furthermora, 3 after five and one-half yearJ of study, stoddard 9 (1962) reported only 43 waterfowl deaths out of a 10 total of 15,251 bird casualties. After eleven years 11 of study at this site, Stoddard and Norris (1967) 12 reported only 75 waterfowl casualties out of a total f 29,451 bird deaths. The vast majority of birds 13 14 involved were such species as warblars, vireos, 15 etc. -- birds generally classified as passerines.
Q. How would you distinguish transmission 7
li es a d towers from the television towers studied?
g A. Transmission lines are neither lighted nor are the towers guyed. Therefore the physical structures studied by these authors are not comparable to an electric transmission lino system. Furthermore, 21 '
these TV towers were 673 feet and 1,010 feet in 22 height, whereas 345 kv transmission towers are normally 23 135 feet in height. The TV towers were lighted with 24
1 three sets of 1,000 candlepower blinker lights and a 2 large (unspecified) number of much weaker three-light -
3 installations, all of which apparently tended to 4 attract migrating passerines on occasion, thus enhancing 5 the likelihood for collisions.
6 Q. Have you examined more recent literature on 7 waterfowl collisions?
8 A. Yes, I have examined papers by, among 9 others, Banks (1979) (Ref. 6), who said annual bird 10 mortality from striking fences, electrical wires, 11 ect., "must be rather low"; Kroodsma (1977) (Ref. 7),
12 who reported that less than one percent of the non-hunting 13 waterfowl deaths near a power plant in Minnesota were 14 due to power line collisions; and all the papers from 15 the three-day workshop at Oak Ridge, Tennessee, called by the U. S. Fish and Wildlife Service in 1978 16 to examine the issue of bird collisions with transmission 77 18
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- g Two papers, in my opinion, put the entire issue in persepctive.
0 The first is the work of Stout and Cornwell 21 (1976) (Ref. 9), who studied at all nonhunting waterfowl 22 l
mortality from 1930 to 1964. They documented only 1,487 23 deaths due to collisions with telephone and power lines 1
1 and concluded that the overall importance of such " kills 2 is probably minimal."
3 Anderson (1978) (Ref. 10) focused on one specific 4 site rather than the entire nation--the Kincaid Power 5 Plant in Illinois. Two 345 kv lines run between two 6 highly attractive waterfowl habitats, the 2,154-acre 7 Lake Sangchris (where as many as 111,000 waterfowl may a be found during peak periods) and a slag pit offering 9 grit and food. The birds fly back and forth across 10 the lines in great numbers between these two habitats.
11 Yet only 343 birds were reported to have collided with 12 these lines during the entire three-year study. This 13 is a " worst-case" study, and even here, the number of 14 deaths is minimal.
15 Q. Dr. Marrack referenced a study by Anderson 16 (1979) (Ref. 11) on changes in forest bird species composition caused by transmission line corridor cuts.
17 Have you read dat su dy?
18 g
A. Yes. It is not germane to the issue of waterfowl collisions. It deals solely with changes in species composition that occur when a forested area is cleared for transmission line right-of-way.
Q. What do you conclude from your review of the scientific literature?
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1 A. It is my professional judgment that the 2 extant literature does not reflect significant problems 3 of waterfowl collisions associated with transmission 4 lines. All studies where the number of losses are 5 compared to the pcpulation present indicate that less 6 than one percent of the population is apt to be lost 7 due to collisions. This is a biologically insignificant 8 loss. As Banks (1979) concluded, after reviewing g hunting and all other human-related bird mortality:
10 "A relatively few species account for most of this 11 mortality but continue to maintain large, harvestable 12 populations, suggesting that the numbers of most bird 13 species are essentially unaffected by the human y activities discussed." (Ref. 6).
g Q. Dr. Marrack has pointed out that HL&P g rerouted one line that was originally planned to g cross the cooling reservoir. Would you explain why?
A. When we selected our original transmission routes for Allens Creek, a segment of one of the routes was to cross the cooling lake. In the original Environmental Report we pointed out that this segment could cause some waterfowl mortalities during adverse weather. It was our opinion, however, that the 23 number of losses would be insignificant. The NRC 24
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l 1 Staff then asked us to quantify the expected number 2 of losses. In response we made a literature search 3 and determined that there was no literature demonstrating 4 that there was a significant problem with waterfowl 5 collisions and that there was no method of developing l 6 a dependable model that could be used to quantify l 7 predictable losses. As a result of our research we
- 8 were able to develop the factors that should be 9 considered in evaluating the potential for waterfowl
- 10 collisions. Based on these factors, we concluded l
l 11 that the number of collisions would be insignificant.
- 12 (ER Section 5.6.4). Nonetheless, we ultimately 13 agreed to move the line segment out of the cooling l
14 lake because of all of the Staff's concerns with the l 15 route. These concerns included, in addition to 16 potential waterfowl collisions, undesirable visual 17 impacts, and potential interference with recreational boating. In my opinion, the latter two problems were 18 g the most compelling reasons for taking the line segment out of the lake area. As I noted previously, l 20 I
subsequent review of the developing literature shows that our professional judgment was sound at the time.
The more detailed studies developed since 1973 show
[ that there is no significant problem with waterfowl 1 collisions, even at specific sites (such as Lake 2 Sangchris) where one might expect a large number of -
3 collisions because of the particular circumstances at 4 that site. Now that there is no line segment crossing 5 the lake, there are no other special or unique areas 6 along the proposed rights-of-way that would have a 7 greater tendency to concentrate waterfowl than other a surrounding areas.
f 9 Q. Dr. Marrack has asserted that HL&P has 10 relocated another line because of the possibility of 11 waterfowl mortality. Would you please explain this 12 situation?
13 A. A portion of the 345 kv line from the South l
( 34 Texas Project to Dow-Velasco was rerouted. No real 15 problem was ever demonstrated. Again, this was a 16 case where HL&P voluntarily agreed to relocate a 17 short portion of line to minimize potential--and I emphasize the word " potential"--waterfowl impacts.
18 e ne n @esdon was o@nally located 19 in the Huntington Wells area on the Perry Ranch.
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1 This area was reputed to be both a sanding area and l 21 roost for large numbers of wintering geese. The proposed location for the 345 kv line was within a l few hundred feet of Huntington Wells. The issue
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1 arose whether this line would pose a significant 2 threat to geese entering and leaving the area. Of -
3 special concern was the claim that probably the 4 largest concentration of Greater Canadian Geese, 5 estimated at about 100 birds, to winter on the Texas 1
6 Coast does so at Huntington Wells. The claimants 7 recommended relocating the line to the north to a minimize potential impact on these birds. When this 9 matter was brought to my attention, I concurred that 10 the line probably was too close to Huntington Wells 11 and that relocation to the north would minimize 12 risks. However, I did not agree with the northernmost 13 relocation route proposed by the claimants. This 14 w uld put the line as close to the reported feeding area f these geese as our original location was to 15 their sanding and roosting area. Relocating the line 16 to the south of Huntington Wells was not desirable as 7
this relocation would have put the line on the northern 18 edge of Perry Marsh, an area utilized by approximately g
65,000 geese and several thousand ducks annually, and would, therefore, present a greater potential risk to waterfowl than it would at the original location.
Thisf issue was finally resolved by mutual agreement on a location approximately 2,500 feet north of 24 1
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1 Huntington Wells, or approximately half-way between 2 the sanding-roosting area and the feeding area, as I 3 had recommended. I know of no comparable problems 4 with the Allens Creek transmission routes.
5 Q. Turning now from the general to the specific, 6 will these two lines under discussion today cause 7 significant waterfowl mortality?
8 A. No, they will not. Thera is nothing in 9 their environmental settings, including the possi-10 bility of some waterfowl feeding along portions of 11 these lines and the possibility of some daily over-12 flights, to suggest that these lines pose any signifi-Cant danger.
3 14 Q. Please describe the waterfowl population in the vicinity of these lines.
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16 A. The Texas coastal plains are a major wintering area for waterfowl in the central flyway. Some 17 species spend the entire winter here, while others I feed briefly, then continue their migrations to l 19
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'. Mexico and South America. The area is attractive to 1 20 waterfowl because of the presence of water and foodstuff, particularly rice fields, etc. The major species to 22 be found locally are blue, snow, white front, and 23 lesser Canadian geese, mallards, pintail, teal, 24 j l
l 1 widgeon, and mottled ducks, to name a few. Different l 2 species arrive and depart on different schedules, of 3 course, but the migration / wintering season generally 4 begins in late August and runs through mid-late 5 March.
6 Q. For what reasons would a waterfowl be 7 likely to fly over one of these power lines?
8 A. I can think of only three. First, they may 9 pass over them in seasonal migration north and south.
10 Second, they may pass over them in daily flights from 11 roosting to feeding areas. Third, they may pass over 12 them during the day while moving from one feeding 13 area to another.
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- l 14 Q. Will the lines pose any threat to waterfowl 15 in seasonal migration?
16 A. No. Migrating waterfowl typically fly at l altitudes of several hundred to several thousand 37 feet, and they make only two passes annually. The 18 g
risk of collision here is so small as to be practically i nonexistent.
Q. What of daily movement from roosting to feeding areas?
A. Again, the risk is very low. The only waterfowl even theoretically at risk would be those 24
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1 that move daily in a north-south pattern over the 2 lines. Only a small percentage of all waterfowl in 3 the area follow that pattern--chiefly those individuals 4 that roost along the coastal marshes, then fly north 5 to the rice fields to feed during the day. Again, 6 these flights are typically at altitudes well above 7 the height of any transmission lines.
8 Q. That leaves only the short hop flights for 9 feeding.
10 A. Yes. And, again, the risk of collision is 11 insignificant. No published study with which I am 12 familiar says lines across waterfowl feeding areas 13 pose a significant threat to waterfowl. This makes 14 sense to anyone familiar with waterfowl feeding 15 habits. First, many species spend their entire days 16 at one site. Second, those that do move around will 17 do so in a random pattern in relation to the line.
18 That is, they are as likely to fly away from the 19 lines or parallel to the lines as across them. And nally, but probably most importantly, waterfowl are 20 simply not prone to fly into transmission lines, g especially in a familiar enviroment, (Refs. 6, 10).
Q. Is it possible to quantify the waterfowl numbers along the two transmission lines?
1 A. No. The data do not lend themselves to the 2 sort of analysis necessary to make such an estimate. -
3 For example, I have examined the figures and tables 4 from the Texas Parks & Wildlife waterfowl reports in 5 an effort to estimate the number of ducks and geese 6 that utilize this area. Unfortunately, the census 7 zones employed by the department are too large to 8 permit reliable estimates of populations in and along 9 the power lines. The zone for ducks that includes 10 the Allens Creek site, for example, stretches from 11 Harris County to San Patricio County near Corpus 12 Christi. The local zone for geese encompasses parts 13 f eight counties and extends from Houston to near 14 Victoria, Texas, approximately 120 miles southwest of 15 Houston. The data are not broken down into sub-zones r regi ns. There is no indication whether the birds 16 17 are more concentrated in one part of the zone than in ther parts. It is my judgment thay any population 18 estimates for the area along these transmission 9
li s, based on these aggregate data, would be meaning-0 less.
21 Q. Can you estimate how many ducks and geese, if any, might be killed by collisions with these 23 lines annually?
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1 A. No. The variables in making such a calculation 2 quickly get out of control, as we learned in attempting -
3 to make such a computation for the cooling reservoir.
l 4 This is a subject that still yields more readily to 1
5 the exercise of well-informed judgment than to any 6 mathematical wizardry. My judgment is that the
! 7 numbers would be so insignificant as to be negligible, 1
8 based on experience elsewhere in the HL&P system, on ,
9 the literature, and on my analysis of the environmental 10 setting of these lines. General feeding areas clearly 11 do not pose the same kind of risks to waterfowl as l
12 was posed by the highly attractive lake and slag pit 13 straddled by the lines at Lake Sangchris, a situation 14 which is highly conducive to concentrating waterfowl, l g as the Lake Sangchris/ slag pit provides water, food, g grit, and a roost, thus satisfying all of the waterfowls' g basic daily requirements in a small area near transmis-sion lines.
g Q. The contention also asks whether an alternative route would be better--a route that follows the
' Brazos River to the south of the site, then goes east 21 and then north to the O'Brien substation. Have you analyzed the possible costs and benefits of such an alternative?
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1 A. Only in the most general way. The route 2 described is so utterly vague that I cannot plot it 3 upon a map, the- elementary first step for analysis.
4 Q. To your knowledge, has Dr. Marrack identified 5 a route for the alternative line he proposed?
6 A. No. I was present at EL&P's deposition of 7 Dr. Marrack, however, and I am aware that he was l
l 3 presented with a map and asked to draw the line. He g refused.
10 Q. So you were unable to plot a specific l
11 route. Did you have any other problems making the 12 comparison?
13 A. Yes. It is not clear from the contention 14 whether the proposed alternative route is suggested 3_o as an alternative for 2C, alone, or for both lines.
16 These lines will have a negligible impact on waterfowl populations. But to attempt to eliminate one, then 17 I reroute other lines to serve the power needs would 18 raise other major environmental issues. It's a poor 9
tradeoff.
20 Q. With these analytical difficulties in mind, have you nevertheless attempted a comparison?
A. Yes. Bearing these problems in mind, I l 24
1 have attempted to make some general comparisons of -
2 the proposed alternative with 2C and with 1A.
3 Intervenor's proposed alternative, wherever 4 it may be, is clearly worse than 2C in terms of i
5 possible impact on waterfowl that fly north and south 6 daily. Intervenor's proposal is simply another way 7 of getting from the same point A to the same point 8 B--a task that necessarily requires a west-to-east 9 crossing. The only geographic variable is to loop 10 the line north or south of a straight line. As 11 stated before, some waterfowl fly north from the 12 coast each day for feeding purposes. As they do so, 13 their numbers decrease as groups drop into various 14 feeding areas. A more northerly route, in other 15 w rds, is likely to be crossed by fewer birds daily l 16 than a more southerly route, due to the settling out l 17 of increasing numbers of birds as they fly north.
8 As for the impact on waterfowl due to daily 9
random movements in feeding acres, no direct comparison 20 is possible because of the uncertainty regarding the l
route of the proposed alternative line. However, the notion o? following the Brazos River is a bad one, 23 both in terms of the effect on waterfowl and in general environmental terms.
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1 As for impact on seasonal migrants, the 2 alternative is neither better nor worse than 2C. As -
3 indicated earlier, these waterfowl normally make only 4 two migratory passes a year, generally at high altitudes.
5 Therefore, as a practical matter, the comparison of I
6 risk becomes one of "never" versus "not at all,"
7 regardless of where the line is sited.
8 Now, to make the same comparisons between 9 the proposed alternative and the Parish route 1A:
10 On the measure of impact on waterfowl 11 resulting from random. movements in feeding areas, lA 12 is clearly preferable. This line is outside of any i
! 13 major utilization areas. (Ref. 12). For the same 14 reason, this line is highly unlikely to harm birds in 15 daily north-south flights; due to the lack of feeding 16 areas in close proximity, birds are likely to pass 17 verhead at safe altitudes on their way to the feeding areas.
18 The impact on seasonal migrants, again, is 9
not important in either case.
l Q. You suggest that the Brazos route raises 21 special problems. Please elaborate.
A. To follow the Brazos River south, then cross the river, as Dr. Marrack proposes, would have l
1 much greater impact on riparian woodlands and on the 2 various animal species associated with this type of 3 habitat than would HIAP's proposed route. Again, to 4 seek to avoid the negligible problem of waterfowl 5 collisions by cutting a swath through river woodlands 6 strikes me as a poor bargain. We must consider all 7 ecological impacts, not just those associated with 8 waterfowl, when environmental assessments are made.
9 Q. Would you please summarize your testimony?
10 A. Based on my experience, the experience of 11 HL&P with similar lines, the literature, and my 12 analysis of the environmental settings of the proposed 13 routes, I conclude, first, that waterfowl collisions 14 are not a major problem along any transmission lines o
with which I am familiar, including those in the HL&P system; second, that the proposed lines 2C and 1A 16 will not pose significant dangers to waterfowl along the Texas Gulf Coast; third, that these lines are 18 i superior to the proposed alternative on the measure of waterfowl impacts; and fourth, that these lines are even more clearly superior to the proposed alter-1 1
native when other impacts are considered.
22 Q. Does this complete your testimony?
A. Yes.
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REFERENCES
- 1. Convention between the United States and Great Britain for the protection of migratory birds, 39 Stat. 1702, art. I, 5 1(a) (1916).
- 2. Scott, Roberts & Cadbury, Bird Deaths from Power l Lines at Dungeness, 63 BRIT. BIRDS 273 (1972).
- 3. Cornwell & Hochbaum, Collisions with Wires--A Source of Anatid Mortality, 83 WILSON BULL. 305 (1971).
- 4. Stoddard, Bird Casualties at a San Leon County, Florida TV Tower: 1955-1961, (Tall Timbers Research Station, Bull. 1, 1962).
- 5. Stoddard & Norris, Bird Casualties at a Leon County, Florida TV Tower: An Eleven-Year Study, (Tall Timbers Research Station Bull. 8, 1967).
- 6. Banks, Human Related Mortality of Birds in the United States, Special Scientific Report--Wildlife No. 215 (U.S. Dept. of the Interior, Fish and Wildlife l Service, 1979).
- 7. Kroodsma, Effects of Powerlines on Raptors and Waterfowl I (paper presented at A.I.B.S. meeting, 1977).
- 8. M. Avery, ed., Impacts of Transmission Lines on i Birds in Flight (U.S. Environmental Protection
! Agency and U. S. Department of the Interior, Sept.,
l 1978).
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- 9. Stout & Cornwell, Nonhunting Mortality in Fledged North American Waterfowl, 40 J. WILDLIFE MANAGEMENT 681 (1976).
- 10. Anderson, Waterfowl Collisions with Power Lines at a Coal-Fired Power Plant, 6 WILDLIFE SOC'Y BULL.
(1978).
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! 11. Anderson, Changes in Forest Bird Species Composition caused by Transmission-line corridor cuts, 33 AM.
BIRDS 3 (1979).
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- 12. Texas Parks & Wildlife Dept., 6 TEX. OUTDOOR RECREATION PLAN (1975).
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