BEFORE THE PUBLIC SERVICE COMMISSION OF

IN THE MATTER OF THE APPLICATION ) OF GAS AND ELECTRIC ) COMPANY FOR A CERTIFICATE OF ) Case No.______PUBLIC CONVENIENCE AND NECESSITY ) FOR THE BUSH RIVER CROSSING 115kV ) REBUILD PROJECT )

APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY

TABLE OF CONTENTS

I. INTRODUCTION...... 1 II. APPLICANT INFORMATION ...... 2 III. INFORMATION IDENTIFIED BY COMAR 20.79.04.01 ...... 3 IV. DESCRIPTION OF THE PROPOSED TRANMISSION LINE (COMAR 20.79.04.02 AND COMAR 20.79.04.03) ...... 7 V. IMPLEMENTATION SCHEDULE ...... 12 VI. ENVIRONMENTAL INFORMATION ...... 12 VII. INFORMATION REQUIRED PURSUANT TO PUA § 7-207 ...... 13

I. INTRODUCTION

Pursuant to the provisions of Section 7-207 of the Public Utility Companies Article of the

Annotated Code of Maryland and Title 20, Subtitle 79 of the Code of Maryland Regulations

(“COMAR”), Baltimore Gas and Electric Company (“Applicant”) submits this Application for a

Certificate of Public Convenience and Necessity (the “Application”) to the Public Service

Commission of Maryland (the “Commission”) to complete the Bush River Crossing 115kV

Rebuild Project (“Bush River Crossing Project” or “Project”). The Project involves the replacement of a 1.3 mile portion of an existing 115kV transmission line (Circuits 110620/110621) that runs from Edgewood to Perryman across the Bush River, in Harford County, Maryland (see

Exhibit 1- Project Location Map).

Filed simultaneously with and in support of this Application is the supporting testimony and accompanying exhibits of three witnesses: (1) the Prepared Direct Written Testimony of Albert

E. Alford, Project Manager for BGE; (2) the Prepared Direct Written Testimony of Robert P. May,

P.E., Project Engineer; and (3) the Prepared Direct Written Testimony of Tennile T. Rubin, Deputy

Director of Environmental Services for McCormick (“MT”). Ms. Rubin is sponsoring the

Project’s Environmental Review Document (“ERD”), a comprehensive document that describes the existing environment of the Project area, presents the Project and how it is to be constructed and operated, and assesses the potential environmental, socioeconomic, cultural, and visual impacts of the Project. In support of its Application, and in accordance with the filing requirements detailed in COMAR 20.79, Applicant submits the following information:

1 II. APPLICANT INFORMATION

A. Name of the Applicant:

The name of the applicant is Baltimore Gas and Electric Company (“BGE”).

B. Address of the Principal Business Office of the Applicant:

Baltimore Gas and Electric Company 2 Center Plaza 110 West Fayette Street Baltimore, Maryland 21201

C. Person Authorized to Receive Notices and Communications:

David E. Ralph Associate General Counsel Baltimore Gas and Electric Company 2 Center Plaza 110 West Fayette Street Baltimore, Maryland 21201

D. Location at which the Public May Inspect a Copy of the Application:

A copy of the Application will be filed with the Commission, and as such, it may be accessed by the public online through the Commission’s website (www.psc.state.md.us) or in print at the Commission, which is located at the following address:

William Donald Schaefer Tower 6 St. Paul Street 16th Floor Baltimore, Maryland 21202

The public may also inspect a copy of the Application at the following location after setting an appointment to do so with the authorized persons listed in Section C of this Application:

Baltimore Gas and Electric Company 2 Center Plaza – 12th Floor 110 West Fayette Street Baltimore, Maryland 21201

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E. Local, State, and Federal Government Agencies Having Approval Authority

Related to Construction or Operation of the Project:

Applicant must obtain a Certificate of Public Convenience and Necessity (“CPCN”) from the Commission in order to proceed with construction of the Project. In addition, and as required by COMAR 20.79.01.04E, Table 1.3-1 in the ERD summarizes the additional licenses, permits, and approvals that are or may be necessary for the construction and operation of the Project, along with the identity of the responsible local, state, and federal agency and the status of any requested approvals, waivers, or variances. All applicable permits and approvals required for the construction and operation of the Project will be obtained by BGE from these agencies. However, because the applications for these permits and approvals require precise technical information regarding facility locations and detailed engineering design, applications to all of these agencies have not been submitted prior to the filing of this Application. The detailed information necessary for a select few of these permits and approvals may not be available until the CPCN either is issued or this proceeding is underway.

III. INFORMATION IDENTIFIED BY COMAR 20.79.04.01

A. COMAR 20.79.04.01 Information for Transmission Lines

1. An explanation of the need for the project in meeting demands for service

BGE has the responsibility to maintain the safety and reliability of its electric system and achieves this through the inspection and maintenance of its existing transmission lines. As a result of these inspections, life expectancy of components of the transmission system, the frequency of line outages, and subsequent repairs, BGE’s Transmission Planning and Transmission Engineering

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Departments have concluded that the seven structures of the Bush River Crossing Project, carrying

Circuits 110620/110621, is a priority transmission circuit in the BGE system to be rebuilt.

The proposed Project, which involves rebuilding the existing transmission line (Circuits

110620/110621) at the Bush River Crossing, is required to improve reliability for communities and critical infrastructure. This transmission line connects to three substations, one of which serves approximately 12,500 customers and one that serves U.S. Army

(“APG”) critical infrastructure directly. In order to address these reliability issues, seven structures

(three steel lattice towers and four wood H-frames) will be replaced with nine steel monopoles at the crossing. The new steel poles replacing the existing lattice towers will be approximately 125-

145 feet higher, resulting in higher spans and clearances which meet current standards and improve safety and minimize sailboat contacts with wires. The galvanized steel monopoles will also include avian deterrents in the design to reduce potential outages caused by nesting. Reducing outages increases reliability to APG, which is one of the largest employers in Harford County.

Replacing the structures will also resolve the issues with degradation of the structures on each shore and within Bush River.

2. A description of the effect of the project on system stability and reliability

The Project will address stability and reliability concerns in several key areas:

1) Improving reliability: From 2009-2019, there have been 12 outages recorded for the entirety of the transmission line, nine of which occurred directly at the Bush River Crossing. The

Project, once completed, will improve the reliability of the Applicant’s 115kV transmission line.

The existing transmission line (Circuits 110620/110621) connects the Perryman Substation to the

Edgewood and Joppatowne Substations. The Edgewood Substation directly serves the APG

Edgewood facility, which employs approximately 24,000 people, and the Joppatowne Substation

4 serves approximately 12,500 customers. The transmission line from Perryman to Joppatowne is approximately 8.8 miles and consists of 107 single circuit wood pole structures, 22 double circuit steel poles, 13 double circuit towers, and 2 single circuit steel poles. The Joppatowne Substation is networked back to the Raphael Road Substation via a 115kV underground transmission line, connected to the Raphael Road 230kV yard via transformer 230-1 (230-115kV). This network connection from Raphael Road to Joppatowne provides a resilient connection into the Perryman area. The rebuild of the existing transmission line at the Bush River Crossing will improve reliability of the transmission line, supporting communities and critical infrastructure.

2) Aging infrastructure: The Existing Circuits 110620/110621 transmission line was constructed in 1951 and has experienced substantial reliability problems through the years due to avian contamination (nest debris, bird droppings, etc.) and degradation. During an inspection in

1990, the three lattice tower structures at the Bush River Crossing (one on either side of the shoreline and one in the river) were found to be degraded. Deterioration was occurring to the steel

H-piles and the concrete pile caps. Repairs on these structures were made in 1991 and project reports indicated an expected lifespan of only 25 years; the line is currently in year 29 following these repairs. The repairs included encapsulation of the steel piles which prevents further inspection of the piles. This aging infrastructure has outlived its useful life. Replacing the structures will resolve the issues with degradation of the structures on each shore and within the

Bush River.

3) Avian interactions: Several avian electrocutions or “bird takes” on the existing line are due to minimal phase-to-ground clearance between the insulator and the tower arm. In these conditions, a bird is able to make contact with the insulator and the tower arm simultaneously, resulting in electrocution. A rebuild would replace the existing towers with poles that have greater

5 phase-to-ground clearance. Additionally, by converting the towers from lattice towers to steel poles, there is expected to be a reduced likelihood of birds nesting on the structure in hazardous areas and therefore an elimination of nest-related issues. An outage in May 2017 led to the discovery of a colony of cormorants on Structure 3242 (the lattice tower located within the Bush

River) and at least 37 nests were documented on the structure. In addition to causing outages, the cormorant colony increases safety concerns when needing to access the tower for maintenance and/or emergency repairs. The new steel poles will include avian-safe clearances between conductor arms to eliminate the opportunity for electrocutions. The steel monopoles will also include avian deterrents in the design to reduce potential outages caused by nesting materials collecting on top of the new structures.

4) Sailboat Contacts: The transmission line also has a history of outages caused by sailboat contact with wires, with documented incidents in 2000 and 2002. The new steel poles will be approximately 140-150 feet higher resulting in higher spans which meet current standards and improve safety so that sailboats do not come in contact with the wires.

3. A description of the consequences if the project is delayed or not approved

If the Project is delayed or not approved, all of the reliability and safety concerns addressed above would continue to go unresolved. In addition, issues with avian contamination, sailboat contact with wires, and degradation of the transmission line could compromise the safety and integrity of the circuit. The new steel poles replacing the existing lattice towers will be approximately 125-145 feet higher, resulting in higher spans and clearances which meet current standards and improve safety and minimize sailboat contacts with wires. The galvanized steel monopoles will also include avian-deterrents in the design to reduce potential outages caused by nesting. Replacing the structures will resolve the issues with degradation of the structures on each

6 shore and within the Bush River. If the identified contingencies are not implemented, the consequences could lead to customer interruptions, most likely in Edgewood, Maryland, and

Joppatowne, Maryland.

4. An explanation of the cost effectiveness of the project, including an estimate of capital

cost and annual operating cost

The capital cost of the Project is estimated to be approximately $10,517,740. The annual operating and maintenance cost associated with the approximately 1.3 mile 115kV overhead transmission line segment that will be constructed as part of the Project is estimated to be approximately $8,496. Additionally, Applicant may be required to pay an annual compensation fee to the State of Maryland for the overhead crossing of the Bush River.

5. A description of the impact of the project on the economies of the State

The Project will sustain the reliability of the electrical system in the State of Maryland and ensure that customers within the Applicant’s electric distribution service territory, including one of Harford County’s largest employers, APG, have a reliable network for transmitting electricity for years to come. The Project is also expected to generate tax revenue and benefit local businesses during construction. In doing so, the Project will have a positive economic impact regionally as well as for the State of Maryland. Section 3.5 of the ERD provides additional detailed information.

IV. DESCRIPTION OF THE PROPOSED TRANMISSION LINE (COMAR

20.79.04.02 AND COMAR 20.79.04.03)

This application involves the rebuild of approximately 1.3 miles of the existing 115kV transmission line (Circuits 110620/110621) across the Bush River in Harford County, Maryland.

The rebuild will take place within BGE’s existing and proposed right-of-way (“ROW”), which includes new easement agreements with Constellation (an Exelon company) and APG on both

7 sides of the Project. The proposed placement of the new steel poles will require additional easements to allow for a shift in the alignment. The shift in the alignment is necessary to accommodate construction of the proposed line while the existing line remains in service.

Additionally, shifting the alignment avoids impacts to the Harford County forced sewer main which runs parallel to the existing 115kV transmission line under the Bush River.

A. Engineering and Construction Features [COMAR 20.79.04.02(A)]

1. Width, Length and Total Acreage of the Right-of-Way

The existing ROW corridor is 130 feet wide and extends approximately 1.3 miles over the

Bush River between Edgewood and Perryman, Maryland. The proposed easements on both sides of the Bush River will range from approximately 30 to 300 additional feet in sections of the Project

ROW resulting in a total ROW acreage of approximately 42 acres.

2. Line Voltage

The operating voltage of the proposed transmission line crossing the Bush River will be

115kV, which is the same as existing.

3. Number of Circuits

There will be two circuits associated with the overhead wire crossing at the Bush River.

4. Number of Circuits Per Structure

Each structure constructed as part of the Project will support one circuit, with the exception of the tower in the Bush River, which will support two circuits.

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5. Structure Type and Dimensions

The Project requires the replacement of four wood H-frame transmission structures (two on each side of the river) and three existing steel lattice structures (one on each shore and one located within the Bush River) with nine self-supporting galvanized steel monopole structures.

The new steel poles replacing the existing lattice towers will range in size from 235 to 255 feet tall. The four steel monopoles replacing the H-frames will be approximately 70 feet tall. For drawings depicting the design and location of the structures, see Subsection 2.2.5 (Structure

Description and Installation) in the ERD.

6. Conductor Configuration and Size

The conductor for the 115kV circuits will consist of 1,590-thousand-circular-mils (kcmil),

54/19 ACSR (Rail) conductor. This conductor is 1.545 inches in diameter and is composed of 54 aluminum strands around a 19-strand steel core.

7. Nominal Capacity (MVA)

The nominal rating for the line after Project completion will be 130MVA/173MVA

Summer Normal/Summer Emergency and 160MVA/205MVA Winter Normal/Winter

Emergency.

8. Nominal Length of Span Between Structures

The proposed length of span between the structures to be constructed on land for the Project are 323 to 384 feet. The length of span from the river structure to the dead-end structures on land are 2,017 feet (Perryman) and 2,048 feet (Edgewood), respectively.

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B. Property or Property Right Acquired or to be Acquired [COMAR 20.79.04.02(B)]

Easement agreements for additional ROW with Constellation and APG are being acquired for the installation of four structures (two structures on each shore of the Bush River) and to allow for a shift in the alignment. A map depicting the proposed final ROW is provided in Exhibit 2.

C. Access Roads for Construction or Maintenance [COMAR 20.79.04.02(C)]

Existing gravel access roads will be utilized on both the Edgewood and Perryman side of the

Project. No construction of new permanent access roads will be required for construction or maintenance of the Project. Where applicable, temporary construction mats will be used for access and equipment staging in wetlands. These mats will be removed in sequence with the completion of construction. Access to the structure in the Bush River will require use of barges, which will come up- river from Curtis Bay (6211 Pennington Ave, Baltimore, Maryland 21226). Crews will access the barges for daily activities from a marina in the area, such as Flying Point Marina (324 Flying Point

Road, Edgewood, Maryland 21040).

D. Location and Identification of the Following Sites, from Which the New Structure

Would Be Clearly Visible [COMAR 20.79.04.02(D)]:

1. Historical

See Section 3.3 (Archaeological, Architectural, and Historical Sites) in the ERD for a discussion on historical sites within the vicinity of the Project Study Area.

2. Institutional Land

See Section 3.4 (Land Use and Aesthetics) in the ERD for a discussion on institutional lands within the vicinity of the Project Study Area.

3. Recreational Areas

See Section 3.4 (Land Use and Aesthetics) in the ERD for a discussion on recreational lands within the vicinity of the Project Study Area.

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4. Aesthetic Areas

See Section 3.4 (Land Use and Aesthetics) in the ERD for a discussion on aesthetics of the

Project Study Area.

5. Archeological

See Section 3.3 (Archaeological, Architectural, and Historical Sites) in the ERD for a discussion on archaeological sites within the vicinity of the Project Study Area.

6. Wildlife Management Areas

See Section 3.2.3 (Aquatic Ecology) and Section 3.2.4 (Terrestrial Ecology) in the ERD for a discussion on wildlife management areas within the vicinity of the Project Study Area.

7. Park or Forest

See Section 3.4 (Land Use and Aesthetics) in the ERD for a discussion on park and forest lands within the vicinity of the Project Study Area.

E. Location and Identification of all Portions of the Right-of-Way Requiring

Construction within the 100-year Floodplain of any Stream [COMAR 20.79.04.02(E)]

The majority of the Project ROW is located within the 100-year tidal floodplain of the Bush

River. See Subsection 3.2.3.3 (Floodplains) and Appendix D (Resource Mapping) in the ERD for the location and identification of all portions of the Project ROW within the 100-year floodplain.

F. Location of Public Airports Within One Mile [COMAR 20.79.04.02(F)]

See Subsection 3.4.1.6 (Transportation) in the ERD for the location of public airports within one mile of the Project Study Area.

G. Depiction of Line Route on Topographic Map [COMAR 20.79.04.02(G)]

See Figure 3.1-3 (Topographic Features of the Project Site and Vicinity) in Section 3.1

(Project Site Location and Description) in the ERD.

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H. Description of Alternative Routes Considered for the Transmission Line [COMAR

20.79.04.03]

See Subsection 1.2.3 (Alternative Analysis) and Appendix B (Alternative Analysis Report) in the ERD for a discussion on the alternative routes considered for the Project.

V. IMPLEMENTATION SCHEDULE

The proposed construction start date for the Project is September 2021. The construction schedule and sequencing for the Project will be developed based on engineering, design, transmission system, and outages. The proposed in-service date for the Project is May 2022.

VI. ENVIRONMENTAL INFORMATION

A. General Description of the Physical, Biological, Aesthetic, and Cultural Features, of

the Site and Adjacent Areas [COMAR 20.79.04.04(A)]

The Project will take place within BGE’s existing and proposed ROW. The physical, biological, aesthetic, and cultural features of the Project ROW and adjacent areas are described in the ERD. For additional information on these features, see Section 3.2 (Biophysical Environment),

Section 3.3 (Archaeological, Architectural, and Historical Sites), and Section 3.4 (Land Use and

Aesthetics) in the ERD.

B. Summary of Environmental and Socioeconomic Effects of Construction and

Operation [COMAR 20.79.04.04(B)]

BGE has contracted McCormick Taylor, an environmental consulting firm, to evaluate field study needs and perform field study work, complete the Environmental Review Document

(ERD), and obtain environmental permits for the Bush River Crossing Project. See Section 4.0

(Summary of Project Impacts) in the ERD. 12

C. Studies of Environmental Impacts [COMAR 20.79.04.04(C)]

The environmental impacts that will result from the Bush River Crossing Project are discussed in detail in the ERD. Copies of all studies of the environmental impacts are included as

Appendices in the ERD, including:

(1) Appendix D (Natural Resource Mapping)

(2) Appendix E (Wetland Delineation Report)

(3) Appendix F (Raptor Nest Survey Report)

(4) Appendix G (RTE Species Survey Report)

(5) Appendix H (Forest Stand Characterization Memo)

(6) Appendix I (EDR Report)

(7) Appendix K (Geotechnical Report)

D. Ability to Conform to Applicable Environmental Standards [COMAR

20.79.04.04(D)]

BGE has extensive experience in siting and constructing transmission facilities within sensitive areas and fully understands the requirements to avoid or minimize impacts to the environment. To accommodate environmental and resource concerns, BGE will work closely with federal, state, and local regulatory authorities. The avoidance and minimization measures that will be implemented during Project construction are discussed in detail in Section 2.4 (Avoidance and

Minimization) in the ERD.

VII. INFORMATION REQUIRED PURSUANT TO PUA § 7-207

PUA § 7-207(e) requires the Commission to give due consideration to several factors prior to granting a CPCN for an overhead transmission line. Applicant provides the following information with regard to those requirements:

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A. Information Required Pursuant to PUA § 7-207 (e)

1. The recommendation of the governing body of each county or municipal corporation

in which any portion of the construction of the overhead transmission line is proposed

to be located

BGE had meetings about the Project with Harford County Executive Barry Glassman on

March 5, 2019, and with Harford County Councilman Johnson from Harford County District A on

September 19, 2019, and Harford County Councilman Beulah from Harford County District F on

October 10, 2019. Additionally, BGE provided a presentation on the Project to the Edgewood

Community Advisory Board on October 10, 2019. A community meeting was held via an audio conference call on April 2, 2020. BGE plans to continue outreach efforts with these local elected officials and community associations.

2. The stability and reliability of the electric system

See Section III.A.2, above.

3. Economics

See Section 4 of the ERD for a discussion on economics of the Project

4. Esthetics

See Section 3.4 (Land Use and Aesthetics) in the ERD for a discussion on aesthetics of the

Project Study Area.

5. Historic sites

See Section 3.3 (Archaeological, Architectural, and Historical Sites) in the ERD.

6. Aviation safety as determined by the Maryland Aviation Administration and the

administrator of the Federal Aviation Administration

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BGE entered tower metrics for each of the nine weathering steel poles to be erected as part of the Project with the Federal Aviation Administration’s (“FAA”) online Notice Criteria Tool, which indicated for each new tower that notice was not necessary under FAA and Maryland

Aviation Authority (“MAA”) rules. Copies of the FAA/MAA results for the nine proposed steel monopoles are attached to the ERD at Appendix A.

7. Air and water pollution

See Sections 3.2.1 and 3.2.3 of the ERD for a discussion on water and air impacts.

B. Information Required Pursuant to PUA § 7-207(f)

PUA § 7-207(f) requires that the Commission give due consideration to certain additional information when determining whether to grant a CPCN for an overhead transmission line.

Applicant provides the following information with regard to those requirements:

1. The need to meet existing and future demand for electric service1

As noted above, the Project involves the rebuild of an existing transmission line segment that is currently part of BGE’s electric transmission system, providing customers with reliable electric service. In order to maintain the line segment and continue to bring electricity to areas in which it is needed, the Project is necessary. BGE does not expect the demand for electricity supply to drop to a point in the future negating the need for the Project. Furthermore, PJM has not identified in any study of a load forecast scenario whereby the transmission line segment is no longer necessary. Accordingly, the Project is needed to meet existing and future demand for electric service.

1 PUA § 7-207(f)(1)(i). PUA § 7-207(f)(1)(ii) does not apply as the Project does not involve a “new overhead transmission line.” See also COMAR 20.79.04.03B.

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2. Compliance with all relevant agreements with PJM Interconnection, LLC and

obligations imposed by the North America Electric Reliability Council and Federal

Energy Regulatory Commission2

BGE agrees to comply with: (1) all relevant agreements with PJM, or its successors, related to the ongoing operation and maintenance of the overhead transmission line; and (2) all obligations imposed by the North America Electric Reliability Council and the Federal Energy Regulatory

Commission related to the ongoing operation and maintenance of the overhead transmission line.

3. Identification of certain site characteristics3

First, the Project will not be constructed on a brownfield site. See ERD Subsection 3.2.5 for additional information. Second, as stated above, the Project will be constructed within BGE’s existing and proposed ROW. Third, the Project ROW is located within the General Industrial zoning district, which is designated for industrial uses. The existing portions of the ROW will not change, and all acquired easements for the Project will comply with zoning requirements.

2 PUA § 7-207(f)(2). 3 PUA § 7-207(f)(3). 16

WHEREFORE, Applicant respectfully requests that the Commission issue a Certificate of Public Convenience and Necessity for the Project, as detailed in this Application, and grant such additional authorizations, waivers, approvals, and other relief as may be necessary for the completion of the Project.

Respectfully submitted,

David E. Ralph

David E. Ralph Associate General Counsel

Christia H. Ravenell Assistant General Counsel

Baltimore Gas and Electric Company 2 Center Plaza 110 West Fayette Street Baltimore, Maryland 21201 Phone: (410) 470-5740 Fax: (443) 213-3206 [email protected] [email protected]

Counsel for Baltimore Gas and Electric Company

Date: April 17, 2020

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EXHIBIT 1

EXHIBIT 2

1

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 17th day of April, 2020, pursuant to COMAR

20.79.02.02 and in accordance with the Commission’s March 16, 2020 Order, the foregoing

Application of Baltimore Gas and Electric Company for a Certificate of Public Convenience and

Necessity for the Bush River Crossing Project was forwarded via email, to the following:

Ben Grumbles, Secretary Maryland Department of the Environment Montgomery Park Business Center 1800 Washington Blvd Baltimore, MD 21230-1710 Email: [email protected]

Robert S. McCord, Secretary Maryland Department of Planning 301 W. Preston Street Suite 1101 Baltimore, MD 21201-2365 Email: [email protected]

Jeannie Haddaway-Riccio, Secretary Maryland Department of Natural Resources Tawes State Office Building C4 580 Taylor Avenue Annapolis, MD 21401-2397 Email: [email protected]

Kelly Schulz, Secretary Maryland Department of Commerce (formerly Maryland Department of Business and Economic Development) 401 East Pratt Street Baltimore, MD 21202 Email: [email protected]

Gregory Slater, Secretary Maryland Department of Transportation 7201 Corporate Center Drive Hanover, MD 21076 Email: [email protected]

Ricky D. Smith, Sr., Executive Director Maryland Aviation Administration P.O. Box 8766 Third Floor, Terminal Building BWI Airport, MD 21240-0766 Email: [email protected]

Tim Smith, Administrator Maryland State Highway Administration 707 North Calvert Street Baltimore, MD 21202 Email: [email protected]

Mary Beth Tung, Director Maryland Energy Administration Montgomery Park Business Center 1800 Washington Blvd., Suite 775 Baltimore, MD 21230 Email: [email protected]

Sondra S. McLemore, Assistant Attorney General Power Plant Research Program 1800 Washington Boulevard, Suite 775 Baltimore, MD 21230 Email: [email protected]

Paula M. Carmody, People’s Counsel Maryland Office of People's Counsel William Donald Schaefer Tower 6 Saint Paul Street, Suite 2102 Baltimore, MD 21202 Email: [email protected]

Genevieve LaRouche, Project Leader U.S. Fish and Wildlife Service Field Office – Northeast Region 177 Admiral Cochrane Drive Annapolis, MD 21401-7307 Email: [email protected]

Barry Glassman, Harford County Executive 220 S. Main Street Bel Air, MD 21014 Email: [email protected]

Andre V. Johnson, County Councilman Harford County Council 212 S. Bond Street, 2nd Floor Bel Air, MD 21014 Email: [email protected]

Patrick S. Vincenti, President Harford County Council 212 s. Bond Street, 2nd Floor Bel Air, MD 21014 Email: [email protected]

Chad R. Shrodes, County Councilman Harford County Council 212 S. Bond Street, 2nd floor Bel Air, MD 21014 Email: [email protected]

James M. Woods, County Councilman Harford County Council 212 S. Bond Street, 2nd Floor Bel Air, MD 21014 Email: [email protected]

Robert S. Wagner, County Councilman Harford County Council 212 S. Bond Street, 2nd Floor Bel Air, MD 21014 Email: [email protected]

Tony “G” Giangiordano, County Councilman Harford County Council 212 S. Bond Street, 2nd Floor Bel Air, MD 21014 Email: [email protected]

Curtis L. Beulah, County Councilman Harford County Council 212 S. Bond Street, 2nd Floor Bel Air, MD 21014 Email: [email protected]

Bradley F. Killian, Director Harford County Department of Planning and Zoning 220 S. Main Street, 2nd floor Bel Air, MD 21014 Email: [email protected]

Senator Jason C. Gallion 414 James Senate Office Building 11 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Mike Griffith 319 House Office Building 6 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Teresa E. Reilly 203 House Office Building 6 Bladen Street Annapolis, MD 21401 Email: [email protected]

Senator J.B. Jennings 423 James Senate Office Building 11 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Lauren Arikan 324 House Office Building 6 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Rick Impallaria 411 House Office Building Annapolis, MD 21401 Email: [email protected]

Delegate Kathy Szeliga 212 House Office Building Annapolis, MD 21401 Email: [email protected]

Senator Robert Cassilly 401 James Senate Office Building 11 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Susan McComas 323 House Office Building 6 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Steve Johnson 215 House Office Building 6 Bladen Street Annapolis, MD 21401 Email: [email protected]

Delegate Mary Ann Lisanti 415 House Office Building 6 Bladen Street Annapolis, MD 21401 Email: [email protected]

Pursuant to restrictions related to the COVID-19 pandemic, the following recipients for whom we do not have email addresses, will be mailed a copy by first-class mail as soon as permissible:

David Bernhardt, Secretary U.S. Department of the Interior 1849 C Street, N.W. Washington DC 20240

Neil Chaterjee, Chairman Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426

Steve Dickson, Administrator Federal Aviation Administration 800 Independence Avenue, SW Washington, D.C. 20591

David E. Ralph David E. Ralph