Hearing on “The West-wide Energy Corridor Process: State and Community Impacts”

NOTE: This statement was submitted in written form for the record of the Hearing. CNPSR did not formally testify at the hearing.

Statement of
John W. “Bill” Wade, Chair, Executive Council
Coalition of National Park Service Retirees

House Subcommittee on National Parks, Forests and Public Lands and
The Committee on Natural Resources
U.S. House of Representatives

Hearing on “The West-wide Energy Corridor Process: State and Community Impacts”
April 15, 2008

On behalf of the members of the Coalition of National Park Service Retirees, we would like to thank you for the opportunity to submit a written statement on the West-wide Energy Corridor Process.

Our non-profit organization now consists of over 640 individuals, all former employees of the National Park Service, bringing with them nearly 20,000 years of experience. Our membership includes much of the top leadership of the National Park Service over the last 15 years, including five former Directors or Deputy Directors of the National Park Service, twenty-five former Regional Directors, or Deputy Regional Directors, twenty-eight former Associate or Assistant Directors and one hundred and twenty former Park Superintendents or Assistant Superintendents. It is their collective concerns that we bring before you today.

The National Park Service was formally established by Congress in 1916:

“to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” [16 U.S.C. 1]

In subsequent congressional reviews of the original authorizing legislation, Congress further mandated in 1978 that:

“The authorization of activities shall be construed and the protection, management, and administration of these areas shall be conducted in light of the high public value and integrity of the National Park System and shall not be exercised in derogation of the values and purposed for which these various areas have been established….” [16 U.S.C. 1a-1]

When many of the National Park Service areas were first enabled, they were in areas quite remote from the affects of development, the air quality and extensive vistas were unimpaired, and the outstanding flora and fauna existed with little impact from outside sources.

As our nation has grown many of these same areas now find themselves with development and industry adjacent to park boundaries resulting in a limiting of natural animal and bird migration patterns, pollutants affecting air quality and vegetation/wildlife stability, and a thirst for more energy sources and the access to those sources creating potential degradation of some of the most outstanding vistas known throughout the world. For example, one of these corridors potentially affects Arches National Park in southeastern Utah where people come from all over the world to experience the outstanding scenery, and we would note that it is also one of the few places, even within the National Park System, where the stars at night are not usually obscured by either air pollution or intrusive lighting from local development.

We support the comments that have been submitted by the National Park Service, particularly those from the Pacific West and Intermountain Regions where most of the parks affected by this proposal are located. Utility corridors are not compatible with the purposes for which the National Park sites were set apart and these new energy corridors should not be established within the boundaries of these parks or adjacent to them where they will impact the resources of those areas in any way. Of particular concern are the impacts on views from prominent visitor viewpoints and the further restrictions or threats to park flora and fauna. We submit that the proposed energy corridors adjacent to, and in some cases through, National Park Service areas do not meet the mandated protection requirements as set forth in congressional legislation previously quoted.

As an organization we recognize the need for, and support the basic premise behind the concept of energy corridors; however, they must be designated only after a careful, in-depth NEPA process which takes into consideration and provides for the proper protection of the nation’s natural and cultural treasures along the way. The fact that some of the proposed corridors actually cross NPS lands shows a complete disregard for the value of the National Parks to the citizens of the United States and a lack of understanding of the resource protections directed by the Congress. The current Draft PEIS does not provide a full range of alternatives nor does it properly address all of the environmental impacts noted in the document. Further, we believe there is no general legal authority to sanction rights-of-way for energy corridors through NPS lands, other than those associated with facilities within the unit. Prior Congressional actions have been careful to avoid granting such authority across parklands.

We would advocate that these energy corridor proposals be further revised to provide for the enhancement of park resources instead of negatively impacting them. Through a careful NEPA process, this could be done in some of the following ways:

1) Provide for more contact with and input from individual federal and state managers of lands affected by the proposals to identify and incorporate resource protection concerns and methodology for implementing them
2) Identify existing energy corridors that currently impact National Park sites (and other areas of national importance such as the National Trails System) and provide for them to be removed or relocated when they are due to be replaced
3) Do not locate any energy corridor within the boundaries of any National Park Service site
4) Do not locate any energy corridor immediately adjacent to any National Park Service area unless it can be shown that adequate alternative routes were reviewed and considered first, and that no other viable option exists
5) In the rare case where it is agreed that there are no other alternatives to designating a corridor adjacent to one of these sites, then a comprehensive, impact-mitigation design process must be required. This design process must look at ways to minimize the impacts created by the utilities including, but not be limited to, keeping all transmission lines below the tops of ridges or mesas, avoiding the crossing of major vistas, utilizing paint colors which blend with the adjacent environment, orientation of towers and other facilities so that the broader or more visible sides are not facing critical view points, location of excavations so they are not easily seen, proper restoration of ground and vegetation after construction for minimized scarring (particularly in desert environments), eliminate any lighting or at a minimum only allow lighting that spreads downward instead of outward, limiting the extent of use (e.g. number of transmission lines) within the corridor, and enacting general maintenance requirements which require minimal or no long-term disturbance of the resources.

It is our hope that prior to the Draft PEIS being finalized, our concerns will be addressed in a supplemental document so that the resources of the National Park System, America’s Crown Jewels, are adequately addressed and protected.

Thank you for allowing hundreds of former National Park Service employees the opportunity to provide you with our heartfelt concerns.