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COMMONWEALTH of Mb HAY 12 P I: 5S g CO DEPARTMEm OF ENVIRONMENTAL QUALITY Street address: 629 East Main Street, Richmond, Virginia 23219 Molly Joseph Ward Mailing address: P.O. Box 1105, Richmond, Virginia 23218 David K. Paylor Secrelaryof Natural Resources Fax: 804-698-4019 - TDD (804) 698-4021 Director www.deq.virginia.gov (8 04 ) 698-4020 1-800-592-5482 May 11, 2016

Mr. Joel H. Peck, Clerk Document Control Center State Corporation Commission 1300 E. Main Street, Tyler Bldg., 1st Floor Richmond, Virginia 23219

RE: Application of Virginia Electric and Power Company (Dominion) for a Certificate of Public Convenience and Necessity: Cunningham-Dooms 500 kV Transmission Line Rebuild, Fluvanna, Albemarle, and Augusta Counties, Case No. PUE-2016- 00020 (reviewed under DEQ #16-0495).

Dear Mr. Peck:

As requested in Mr. William H. Harrison's, March 3, 2016 letter (received March 7, 2016), the Department of Environmental Quality (DEQ) has coordinated the review of the above-referenced application, focusing on the DEQ supplement found in the application. The purpose of the review is to develop information for State Corporation Commission (SCC) staff about potential impacts to natural and cultural resources associated with the proposed project. Based on comments submitted by reviewers, we are providing a summary of potential impacts to these resources from construction and operation of the electric transmission line as well as recommendations for minimizing those impacts and for compliance with applicable legal requirements. This report includes copies of the comments submitted by reviewers.

Thank you for the opportunity to review the application for SCC certification. We trust that you will find our report helpful in your review process. If you have questions, please do not hesitate to call me at (804) 698-4204 or Julia Wellman at (804) 698-4326.

Sincerely,

Bettina Sullivan, Manager Environmental Impact Review and Long Range Priorities Program

Attachments Joel H. Peck DEQ #16-0495 PUE-2016-00020 Page 2 ec: William H. Harrison,.SCC Bonnie Riedesel, Central Shenandoah Planning District Commission Charles Boyles, Thomas Jefferson Planning District Commission Timothy Fitzgerald, Augusta County Steven Nichols, Fluvanna County Thomas C. Foley, Albemarle County Charlotte McAfee, Dominion Amy Ewing, DGIF Keith Tignor, VDACS Robbie Rhur, DCR Roy Soto, VDH Roger Kirchen, DHR David Spears, DMME Greg Evans, DOF Tony Watkinson, VMRC Randy Owen, VMRC Chip Ray, VDOT James Cromwell, VDOT Elizabeth Jordan, VDOT Susan Simmers, DOAV Martha Little, VOF © ©

a a COMMONWEALTH of VIRGINIA ©9 ©9 DEPARTMENT OF ENVIRONMENTAL QUALITY Street address: 629 East Main Street, Richmond, Virgin ia 23219 Molly Joseph Ward Mailing address: P.O. Box 1105, Richmond, Virginia 23218 David K. Paylor Secretaryof Natural Resources Fax: 804-698-4019-TDD (804) 698-4021 Director www.deq.virginia.gov (8 04 ) 698-4020 1-800-592-5482

COMMENTS OF THE DEPARTMENT OF ENVIRONMENTAL QUALITY Concerning the Application of Virginia Electric and Power Company (Dominion) for a Certificate of Public Convenience and Necessity: Cunningham-Dooms 500 kV Transmission Line Rebuild, Fluvanna, Albemarle, and Augusta Counties, Case No. PUE-2016-00020 (reviewed under DEQ #16-0495).

The following comments are intended to provide technical assistance to the State Corporation Commission (SCC) in evaluating the project. The following agencies, locality and planning district commissions joined in this review:

Department of Environmental Quality Department of Game and Inland Fisheries Department of Conservation and Recreation Department of Health Department of Historic Resources Marine Resources Commission Department of Transportation Department of Aviation Virginia Outdoors Foundation Augusta County Thomas Jefferson Planning District Commission Central Shenandoah Planning District Commission

The Department of Agriculture and Consumer Services, Department of Mines, Minerals and Energy, Department of Forestry, Fluvanna County and Albemarle County also were invited to comment.

The information considered in this review includes Dominion's Application for Approval and Certification of Electric Facilities, Cunningham-Dooms 500 kV Transmission Line Rebuild, Case No. PLIE-2016-00020, focusing on the information in the DEQ supplement. Joel H. Peck p DEQ #16-0493 m PUE-2016-00020 m Page 2 in A PROJECT DESCRIPTION © <© © Dominion submitted an application to the SCC for a certificate of public convenience ®8 and necessity to rebuild the existing 500 kilovolt (kV) Cunningham-Dooms Line #534 transmission line in Virginia. Dominion plans to rebuild approximately 32.7 miles of the line, entirely within its existing right-of-way. The line traverses three counties in Virginia: Augusta (approximately 4.2 miles), Albemarle (approximately 25.1 miles) and Fluvanna (approximately 3.4 miles). The rebuild portion is located between the existing Cunningham Switching Station in Fluvanna County and Dooms Substation in Augusta County. The line has been in continuous use since the 1960s. The existing right-of-way contains multiple circuits and varies in width from a minimum of 150 feet to a maximum of 292 feet. No new easements will be required for the rebuild project. The right-of-way is currently cleared and maintained for existing transmission facility operation. Minimal clearing of existing access roads may be necessary in these areas to support construction activities for the rebuild project. Although the proposed finish is different to address the structural issues experienced with COR-TEN® weathering steel on the Company's 500 kV system, Dominion states that the proposed lattice towers are similar to the existing weathering and galvanized steel lattice towers and will allow the rebuild and uprate of the existing 500 kV line. Figures in the application state that the approximate average heights of the proposed 500 kV line towers will be taller than the existing 500 kV line towers. The general character of the project area is predominantly rural with agricultural and scattered residential uses. The right-of-way crosses the Shenandoah National Park, including Skyline Drive and the Appalachian Trail, in Augusta County and a portion of National Park Service Property in Albemarle County. Joel H. Peck p DEQ #16-0493 ®) PUE-2016-00020 @ Page 3 y=I

LIST OF PERMITS OR APPROVALS «

The following permits and approvals are likely to be necessary as prerequisites to project construction. The details of these requirements appear in the "Regulatory and Coordination Needs" section of these comments.

1. Water Permits (see "Regulatory and Coordination Needs", item 1, page 30).

a. Section 404 permit (e.g. Nationwide Permit 12, if appropriate). Required pursuant to the federal Clean Water Act and issued by the U.S. Army Corps of Engineers for impacts to jurisdictional wetlands and/or waters of the United States. b. Virginia Water Protection Permit (9VAC25-210 et seq.). Issued by the Department of Environmental Quality (DEQ) for impacts to waters and jurisdictional wetlands, including isolated wetlands.

2. Subaqueous Lands Management (see "Regulatory and Coordination Needs", item 2, page 30).

a. Subaqueous Lands Permit pursuant to Section 28.2-1204 of the Code of Virginia. Issued by the Virginia Marine Resources Commission for encroachments in, on or over state-owned subaqueous beds.

3. Erosion and Sediment Control and Stormwater Management Plans (see "Regulatory and Coordination Needs," item 3, page 30).

a. General erosion and sediment control specifications pursuant to Virginia Code § 62.1-44.15:55. General erosion and sediment control specifications are subject to annual approval by DEQ. b. Erosion and Sediment Control Plans for construction of facilities not covered under Virginia Code § 62.1-44.15:55 are subject to approval by the appropriate plan approving authority.

4. Stormwater Management Permit (see "Regulatory and Coordination Needs," item 4, page 30).

a. Virginia Stormwater Management Program (VSMP) General Permit for Discharges of Stormwater from Construction Activities (9VAC25-880-70 et seq.) of the Virginia Stormwater Management Program Permit Regulations (9VAC25-870 et seq.) involving land disturbance of 1 acre or more. Coverage under this general permit is approved by DEQ.

5. Air Quality Permits or Requirements (see "Regulatory and Coordination Needs," item 5, pages 30 - 31). Joel H. Peck p DEQ #16-0495 © PUE-2016-00020 <© Page 4 & a. Open Burning (9VAC5-130 et seq.). For open burning involving demolition <0 debris. ^ b. Fugitive dust emissions (9VAC5-50-60 et seq.). Governs abatement of visible emissions. c. Fuel-burning equipment (9VAC5-80, Article 6, Permits for New and Modified Sources). Governs the installation of fuel-burning equipment (boilers, generators, compressors, etc.) or any other air pollution emitting equipment.

6. Solid and Hazardous Waste Management (see "Regulatory and Coordination Needs," item 6, pages 31 - 32).

a. Applicable state laws and regulations include: • Virginia Waste Management Act (Code of Virginia Section 10.1-1400 et seq.); • Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC20- 60); • Virginia Solid Waste Management Regulations (VSWMR) (9VAC20-81); and • Virginia Regulations for the Transportation of Hazardous Materials (9VAC20-110).

b. Applicable Federal laws and regulations include: • Resource Conservation and Recovery Act (RCRA), 42 U.S.C. Section 6901 et seq., and the applicable regulations contained in Title 40 of the Code of Federal Regulations; and • U.S. Department of Transportation Rules for Transportation of Hazardous materials (49 CFR Part 107).

7. Protected Species Legislation (see "Regulatory and Coordination Needs," item 8, page 32).

a. The Federal Endangered Species Act and Virginia protected species legislation may apply if there is any taking of protected species. The applicant must comply with the Federal Endangered Species Act (16 U.S.C. sections 1531 etseq.), Virginia protected species legislation (Virginia Code §29.1-563 et seq.), and the Virginia Endangered Plant and Insect Species Act of 1979 as amended (Chapter 39 of Virginia Code Section 3.1-1020 through 1030).

8. Open-Space Land Act (see "Regulatory and Coordination Needs," item 9, page 32).

a. Virginia Code §10.1-1704 (1950), as amended, requires that land designated as open space shall not be converted or diverted from open-space land use Joel H. Peck p DEQ #16-0498 0) PUE-2016-00020 ig) Page 5 yi

unless the public body that designated the land as open-space finds that the <© conversion or diversion meets several criteria. J®

9. Historic and Archaeological Resources (see "Regulatory and Coordination Needs," item 11, page 32).

a. Section 106 of the National Historic Preservation Act of 1966, as amended, and its implementing regulation 36 CFR 800 requires that federally licensed and permitted projects consider its effects on properties that are listed or eligible for listing on the National Register of Historic Places. Section 106 applies if there is federal involvement such as the issuance of a Section 404 Clean Water Act permit, including Nationwide Permits. The applicability of Section 106 to the entire project or any portion thereof must be determined by the responsible federal agency.

10. Virginia Department of Transportation (VDOT) Right-of-Way Permit (see "Regulatory and Coordination Needs," item 12, page 33).

a. The General Rules and Regulations of the Commonwealth Transportation Board (24VAC30-151) are adopted pursuant to the authority of § 33.1-12 of the Code of Virginia. These rules and regulations provide that no work of any nature shall be performed on any real property under the ownership, control or jurisdiction of VDOT until written permission has been obtained from VDOT.

11. Aviation (see "Regulatory and Coordination Needs," item 13, page 33).

a. Form 7460-1 should be submitted to the Federal Aviation Administration if a proposed development is 200 feet above ground level or within 20,000 linear feet of a public use airport pursuant to Title 14 CFR Part 77 or involve any construction or alteration at any height greater than the imaginary surfaces identified in the Federal Air Regulations Part 77.

12. State Corporation Commission Consideration of Local Comprehensive Plans (see "Regulatory and Coordination Needs," item 15, page 33).

a. The Code of Virginia Section 56-46.1 A states, "In every proceeding under this subsection, the Commission shall receive and give consideration to all reports that relate to the proposed facility by state agencies concerned with environmental protection; and if requested by any county or municipality in which the facility is proposed to be built, to local comprehensive plans that have been adopted pursuant to Article 3 (§ 15.2-2223 et seq.) of Chapter 22 of Title 15.2." Joel H. Peck p DEQ #16-0493 PUE-2016-00020 <0 Page 6 m & SUMMARY OF RECOMMENDATIONS © a Based on the information and analysis submitted by reviewing agencies, we have <39 m several recommendations for consideration by the SCC in its deliberations on the approval and certification of electric transmission facilities. These recommendations are in addition to requirements of federal, state or local law or regulations listed above. The rationale for these recommendations is discussed in the remainder of these comments, specifically in the Environmental Impacts and Mitigation section.

A summary of recommendations follows:

• Conduct an on-site delineation of all wetlands and stream crossings within the project area with verification by the U.S. Army Corps of Engineers, using accepted methods and procedures, for areas that do not have confirmed field delineations and follow DEQ's recommendations to avoid and minimize impacts to wetlands and streams (Environmental Impacts and Mitigation, item 1(c), pages 8-10).

• Reduce solid waste at the source, reuse it and recycle it to the maximum extent practicable (Environmental Impacts and Mitigation, item 5(c), page 14).

• Coordinate with the Department of Conservation and Recreation's (DCR) Division of Natural Heritage regarding its recommendations to protect natural heritage resources as well as for updates to the Biotics Data System database (Environmental Impacts and Mitigation, item 6(e), page 17).

• Coordinate with the DCR Karst Program regarding its recommendations to protect karst features (Environmental Impacts and Mitigation, item 6(e), page 17).

• Coordinate with the Department of Game and Inland Fisheries regarding its recommendations for a mussel survey and to protect other wildlife resources (Environmental Impacts and Mitigation, item 7(c), pages 18-19).

• Coordinate with the Virginia Outdoors Foundation regarding its recommendations to protect open-space properties (Environmental Impacts and Mitigation, item 8(e), page 22).

• Coordinate with the DCR Division of Planning and Recreational Resources regarding its recommendations to protect scenic and recreational resources (Environmental Impacts and Mitigation, item 9(c), page 23).

• Coordinate with the Department of Historic Resources regarding its recommendations to protect historic and archaeological resources (Environmental Impacts and Mitigation, item 10(d), page 24). Joel H. Peck p DEQ #16-0498 Si PUE-2016-00020 <31 Page 7 fefl & • Coordinate with the Department of Aviation regarding its recommendations to ® ensure airport safety (Environmental Impacts and Mitigation, item 12(d), page 26).

• Coordinate with the Department of Health on the implementation of mitigation measures to protect water supplies (Environmental Impacts and Mitigation, item 13(c), pages 27-28).

• Follow the principles and practices of pollution prevention to the maximum extent practicable (Environmental Impacts and Mitigation, item 14, page 28).

• Limit the use of pesticides and herbicides to the extent practicable (Environmental Impacts and Mitigation, item 15, page 28).

• Coordinate with the Thomas Jefferson Planning District regarding its request for consideration of structures to allow broadband service use (Environmental Impacts and Mitioation. item 16(b), page 29). Joel H. Peck P DEQ #16-0498 © PUE-2016-00020 <© Page 8 Ul

ENVIRONMENTAL IMPACTS AND MITIGATION © a 1. Water Quality and Wetlands. The DEQ supplement (page 3) states that the majority of the approximately 600 acres of right-of-way for the rebuild project has no probability of wetland occurrence.

1(a) Agency Jurisdiction. The State Water Control Board promulgates Virginia's water regulations, covering a variety of permits to include Virginia Pollutant Discharge Elimination System Permit, Virginia Pollution Abatement Permit, Surface and Groundwater Withdrawal Permit, and the Virginia Water Protection (VWP) Permit. The VWP Permit is a state permit which governs wetlands, surface water and surface water withdrawals/impoundments. It also serves as § 401 certification of the federal Clean Water Act § 404 permits for dredge and fill activities in waters of the United States. The VWP Permit (VWPP) Program is under the Office of Wetlands and Stream Protection (OWSP) within the DEQ Division of Water Permitting. In addition to central office staff who review and issue VWP permits for transportation and water withdrawal projects, the six DEQ regional offices perform permit application reviews and issue permits for the covered activities.

1(b) Agency Findings. The DEQ OWSP completed a wetland impact consultation for the proposed project on April 1, 2016. According to an offsite wetland impact consultation report, prepared for Dominion by Stantec Consulting Services, Inc. (Stantec) and dated October 30, 2015, both wetland areas and stream corridors were identified within the proposed transmission alignments. The project area is entirely in existing right-of-way, and 23.76 miles of the overall rebuild project area have previously been delineated and confirmed. Areas of confirmed jurisdictional resources within the project area include 5.63 acres of wetlands and 20,064 linear feet of stream. Stantec performed a desktop review of the remaining project area and identified approximately 6.33 acres of wetlands and 3,410 linear feet of stream channel. Additionally, the review includes the wetland area probability of occurrence in the potential jurisdictional features with 0.30 acres of high probability, 2.76 acres of medium probability and 3.27 acres of low probability. The DEQ Valley Regional Office (VRO) will make the final permitting decisions.

1(c) Agency Recommendations. Based upon review of all the information provided by Dominion, DEQ has the following additional recommendations:

• Prior to commencing project work, all wetlands and streams within the project corridor should be field delineated prior to detailed engineering, clearing activities, and construction and verified by the U.S. Army Corps of Engineers (Corps), using accepted methods and procedures. DEQ OWSP (email, H. Schul/J. Wellman, May 4, 2016) states that this recommendation applies to the areas that do not have confirmed field delineations. • Timbering debris should not be placed in wetlands or streams. Joel H. Peck P DEQ #16-0493 @> PUE-2016-00020 @ Page 9 tR

• Structures should be sited to avoid wetlands to the extent practicable and should J® be sited outside of stream channels. $0 • Wetland and stream impacts should be avoided and minimized to the maximum ©0 extent practicable. Stream impacts should be minimized or avoided by spanning the transmission line across each stream. No foundations should be placed within streambeds. Where access is required to cross a wetland, removable mats should be used to reduce compaction and rutting. Towers should be placed to avoid wetlands, wherever possible. To the extent where any footings must be installed in wetlands, each footing should occupy the minimum space necessary. When excavation for a structure is necessary in a wetland, excess spoil should not be disposed of in adjacent wetland areas unless authorized by a state or federal wetland permit. • If the scope of the project changes, additional review will be necessary by DEQ OWSP. • At a minimum, compensation for impacts to State Waters, if necessary, should be in accordance with all applicable state wetland regulations and wetland permit requirements, including the compensation for permanent conversion of forested wetlands to emergent wetlands. • Any temporary impacts to surface waters associated with this project should require restoration to pre-existing conditions. • No activity may substantially disrupt the movement of aquatic life indigenous to the water body, including those species, which normally migrate through the area, unless the primary purpose of the activity is to impound water. Culverts placed in streams must be installed to maintain low flow conditions. No activity may cause more than minimal adverse effect on navigation. Furthermore the activity must not impede the passage of normal or expected high flows and the structure or discharge must withstand expected high flows. • Erosion and sedimentation controls should be designed in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992. These controls should be placed prior to clearing and grading and maintained in good working order to minimize impacts to state waters. These controls should remain in place until the area is stabilized and should then be removed. Any exposed slopes and stream banks should be stabilized immediately upon completion of work in each permitted area. All denuded areas should be properly stabilized in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992. • No machinery may enter surface waters, unless authorized by a VWP permit. • Heavy equipment in temporarily impacted surface waters should be placed on mats, geotextile fabric, or other suitable material, to minimize soil disturbance to the maximum extent practicable. Equipment and materials should be removed immediately upon completion of work. • Activities should be conducted in accordance with any time-of-year restriction(s) as recommended by the Department of Game and Inland Fisheries (DGIF), the Department of Conservation and Recreation (DCR), or the Virginia Marine Resources Commission (VMRC). The permittee should retain a copy of the Joel H. Peck P DEQ #16-0495 PUE-2016-00020 <© Page 10 I/* & agency correspondence concerning the time-of-year restriction(s), or the lack @ thereof, for the duration of the construction phase of the project. ^ • All construction, construction access, and demolition activities associated with m this project should be accomplished in a manner that minimizes construction materials or waste materials from entering surface waters, unless authorized by a permit. Wet, excess, or waste concrete should be prohibited from entering surface waters. • Herbicides used in or around any surface water should be approved for aquatic use by the U.S. Environmental Protection Agency (EPA) or the U.S. Fish and Wildlife Service (FWS). These herbicides should be applied according to label directions by a licensed herbicide applicator. A non-petroleum based surfactant should be used in or around any surface waters. • Consider mitigating impacts to forested or converted wetlands by establishing new forested wetlands within the impacted watershed.

1(d) Requirements. If the project qualifies for a Nationwide Permit 12 (NWP 12) from the Corps, then a VWP permit is not necessary. If the applicant does not obtain a NWP 12, then a VWP permit may be necessary.

A Joint Permit Application (JPA) for a VWP permit must be submitted to DEQ for approval in accordance with 9VAC25-210-50 (see item 2 in the Environmental Impacts and Mitigation section for information on submitting a JPA).

2. Subaqueous Lands Impacts. According to the DEQ supplement (page 2), the project area includes streams.

2(a) Agency Jurisdiction. The Virginia Marine Resources Commission regulates encroachments in, on or over state-owned subaqueous beds as well as tidal wetlands pursuant to Virginia Code § 28.2-1200 through 1400.

The VMRC serves as the clearinghouse for the JPA used by the:

• Corps for issuing permits pursuant to Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act; • DEQ for issuance of a VWP permit; • VMRC for encroachments on or over state-owned subaqueous beds as well as tidal wetlands; and • local wetlands board for impacts to wetlands.

The VMRC will distribute the completed JPA to the appropriate agencies. Each agency will conduct its review and respond.

2(b) Requirement. If any portion of the project involves any encroachments channelward of ordinary high water along natural rivers and streams above the fall line Joel H. Peck H DEQ # .16-049S ® PUE-2016-00020 Page 11 tR or mean low water below the fall line, a permit may be required from VMRC. Any <© jurisdictional impacts will be reviewed by VMRC during the JPA process. ® 09 2(c) Agency Recommendation. Coordinate with VMRC regarding the submittal of a JPA as necessary.

3. Erosion and Sediment Control and Stormwater Management. The DEQ supplement (page 8) states that erosion and sediment control measures are required to be in place prior to construction.

3(a) Agency Jurisdiction. The DEQ Office of Stormwater Management (OSM) administers the Virginia Erosion and Sediment Control Law and Regulations (VESCL&R) and the Virginia Stormwater Management Law and Regulations (VSWML&R).

3(b) Requirements.

3(b)(i) Erosion and Sediment Control Annual Specifications, Stormwater Management and Local Program Compliance. In accordance with §62.1-44.15 et seq., electric, natural gas and telephone utility companies, interstate and intrastate natural gas pipeline companies, and railroad companies shall, and authorities created pursuant to § 5.2-5102 may, file general erosion and sediment control standards and specifications annually with DEQ for review and approval. Such standards and specifications shall be consistent with the requirements of this article and associated regulations and the Erosion and Sediment Control Law and Stormwater Management Act (§ 62.1-44.15:24 et seq.) and associated regulations where applicable. The specificatipns shall apply to: • Construction, installation, or maintenance of electric transmission, natural gas, and telephone utility lines and pipelines, and water and sewer lines; and

• Construction of the tracks, rights-of-way, bridges, communication facilities, and other related structures and facilities of the railroad company. Construction of company buildings, facilities, and other structures are not covered by §62.1-44.15:55, and therefore, must comply with the requirements of the appropriate local erosion and sediment control program.

Dominion must have a certified Responsible Land Disturber in charge of and responsible for carrying out the project-specific erosion and sediment control plan and the land-disturbing activity. Dominion must contact [email protected] two weeks prior to land disturbance. Questions regarding annual erosion and sediment control specifications should be directed to DEQ.

3(b)(ii) Virginia Stormwater Management Plan General Permit for Construction Activities (VAR10). The operator or owner of construction activities involving land disturbance equal to or greater than one acre must register for coverage under the Joel H. Peck DEQ #16-0493 PUE-2016-00020 Page 12

General Permit for Discharges of Stormwater from Construction Activities and develop a project-specific stormwater pollution prevention plan (SWPPP). Construction activities requiring registration also include the land disturbance of less than one acre of total land area that is part of a larger common plan of development or sale if the larger common plan of development will ultimately disturb equal to or greater than one acre. The SWPPP must be prepared prior to submission of the registration statement for coverage under the general permit, and the SWPPP must address water quality and quantity in accordance with the Virginia Stormwater Management Plan (VSMP) Permit Regulations. General information and registration forms for the general permit are available on DEQ's website at http://deq.virginia.gov/ProgramsAA/ater/ StormwaterManagement.aspx.

4. Air Quality. The DEQ supplement (pages 1 and 2) states that Dominion does not expect to burn cleared material and will control fugitive dust during construction in accordance with DEQ regulations.

4(a) Agency Jurisdiction. DEQ's Air Division, on behalf of the State Air Pollution Control Board, is responsible for developing regulations that implement Virginia's Air Pollution Control Law. DEQ is charged with carrying out mandates of the state law and related regulations as well as Virginia's federal obligations under the Clean Air Act as amended in 1990. The objective is to protect and enhance public health and quality of life through control and mitigation of air pollution. The division ensures the safety and quality of air in Virginia by monitoring and analyzing air quality data, regulating sources of air pollution, and working with local, state and federal agencies to plan and implement strategies to protect Virginia's air quality. The appropriate regional office is directly responsible for the issuance of necessary permits to construct and operate all stationary sources in the region as well as monitoring emissions from these sources for compliance. As a part of this mandate, environmental impact reports of projects to be undertaken in the state are also reviewed. In the case of certain projects, additional evaluation and demonstration must be made under the general conformity provisions of state and federal law.

4(b) Ozone Attainment Area. According to the DEQ Air Division, the project is located in an ozone attainment area.

4(c) Requirements.

4(c)(i) Fugitive Dust. During construction, fugitive dust must be kept to a minimum by using control methods outlined in 9VAC5-50-60 et seq. of the Regulations for the - Control and Abatement of Air Pollution. These precautions include, but are not limited to, the following:

• Use, where possible, water or chemicals for dust control; • Install and use hoods, fans and fabric filters to enclose and vent the handling of dusty materials; Joel H. Peck H DEQ #16-0493 0) PUE-2016-00020 O Page 13 ^

• Cover open equipment for conveying materials; and ® • Promptly remove spilled or tracked dirt or other materials from paved streets , eg and remove dried sediments resulting from soil erosion.

4(c)(ii) Open Burning. If project activities change to include open burning or the use of special incineration devices are employed in the disposal of land-clearing debris during demolition and construction, these activities must meet the requirements under 9VAC5- 130 et seq. for open burning. Whereas, the regulation provides for, but does not require, the local adoption of a model ordinance concerning open burning, Dominion should contact the appropriate locality to determine what local requirements, if any, exist. Some applicable provisions of the regulation include, but are not limited to:

• All reasonable effort shall be made to minimize the amount of material burned, with the number and size of the debris piles; • The material to be burned shall consist of clean burning demolition material; • The burning shall be at least 500 feet from any occupied building unless the occupants have given prior permission, other than a building located on the property on which the burning is conducted; • The burning shall be conducted at the greatest distance practicable from highways and airfields; • The burning shall be attended at all times and conducted to ensure the best possible combustion with a minimum of smoke being produced; • The burning shall not be allowed to smolder beyond the minimum period of time necessary for the destruction of the materials; and • The burning shall be conducted only when the prevailing winds are away from any city, town or built-up area.

4(c)(iii) Fuel-burning Equipment. The installation of fuel-burning equipment (boilers, generators, compressors, etc.) or any other air pollution emitting equipment may be subject to 9 VAC 5-80, Article 6, Permits for New and Modified sources.

5. Solid and Hazardous Waste Management. The DEQ supplement (page 4) includes results of a database search and states that waste sites were not identified in the right-of-way.

5(a) Agency Jurisdiction. Solid and hazardous wastes in Virginia are regulated by DEQ, the Virginia Waste Management Board and the Environmental Protection Agency (EPA). They administer programs created by the federal Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response Compensation and Liability Act (CERCLA), commonly called Superfund, and the Virginia Waste Management Act. DEQ administers regulations established by the Virginia Waste Management Board and reviews permit applications for completeness and conformance with facility standards and financial assurance requirements. All Virginia localities are required, under the Solid Waste Management Planning Regulations, to identify the strategies they will follow on the management of their solid wastes to include items such Joel H. Peck [=5 DEQ #16-0493 0 PUE-2016-00020 ^ Page 14 l/i as facility siting, long-term (20-year) use, and alternative programs such as materials <© recycling and composting. ^ m 5(b) Database and Data File Search. The DEQ Division of Land Protection and Revitalization (DLPR) states that the application addresses solid and hazardous waste issues and includes a search of waste-related data bases.

5(c) Agency Recommendations. DEQ encourages all projects and facilities to implement pollution prevention principles, including:

• the reduction, reuse and recycling of all solid wastes generated; and • the minimization and proper handling of generated hazardous wastes.

5(d) Requirements.

• Contact DEQ VRO if improperly disposed solid or hazardous wastes, or petroleum contaminated soils, are encountered during construction and follow applicable federal, state and local regulations for disposal. • If applicable, all structures being demolished should be checked as appropriate for asbestos-containing materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or LBP are found, in addition to the federal waste-related regulations mentioned above, state regulations 9VAC20-81-620 for ACM and 9VAC20-60-261 for LBP must be followed. • All solid wastes, hazardous wastes, and hazardous materials, including construction and demolition wastes and universal wastes must be managed in accordance with all applicable federal, state, and local environmental regulations.

6. Natural Heritage Resources. According to the DEQ supplement (page 6), Dominion's agents requested comments from DCR regarding the proposed project.

6(a) Agency Jurisdiction.

6(a)(i) Agency Jurisdiction - Natural Heritage Resources. The mission of DCR is to conserve Virginia's natural and recreational resources. The DCR Division of Natural Heritage (DNH) mission is to conserve Virginia's biodiversity through inventory, protection and stewardship. The Virginia Natural Area Preserves Act, 10.1-209 through 217 of the Code of Virginia, was passed in 1989 and codified OCR's powers and duties related to statewide biological inventory: maintaining a statewide database for conservation planning and project review, land protection for the conservation of biodiversity, and the protection and ecological management of natural heritage resources (the habitats of rare, threatened, and endangered species, significant natural communities, geologic sites, and other natural features). Joel H. Peck DEQ #16-0493 m PUE-2016-00020 ^ Page 15 y=i

6(a)(ii) Agency Jurisdiction - Threatened and Endangered Plant and Insect a Species. The Endangered Plant and Insect Species Act of 1979, Chapter 39 §3.1-1020 <© through 1030 of the Code of Virginia, as amended, authorizes Virginia Department of Agriculture and Consumer Services (VDACS) to conserve, protect and manage endangered and threatened species of plants and insects. The VDACS Virginia Endangered Plant and Insect Species Program personnel cooperates with the FWS, DCR DNH and other agencies and organizations on the recovery, protection or conservation of listed threatened or endangered species and designated plant and insect species that are rare throughout their worldwide ranges. In those instances where recovery plans, developed by FWS, are available, adherence to the order and tasks outlined in the plans are followed to the extent possible. VDACS has regulatory authority to conserve rare and endangered plant and insect species through the Virginia Endangered Plant and Insect Species Act. Under a Memorandum of Agreement established between the VDACS and DCR, DCR has the authority to report for VDACS on state-listed threatened and endangered plant and insect species.

6(b) Agency Findings - Natural Heritage Resources. DCR DNH states that the Middle Fork - Cunningham Creek Stream Conservation Unit (SCU) is crossed four times by the proposed line rebuild, and DCR emphasizes the importance of implementing appropriate erosion and sediment control measures.

Additional comments from DCR DNH are listed below and organized by 1:24,000 quadrangles:

Waynesboro East Quad: This project is situated on karst-forming carbonate rock and can be characterized by sinkholes, caves, disappearing streams, and large springs. Discharge of runoff to sinkholes or sinking streams, filling of sinkholes, and alteration of cave entrances can lead to surface collapse, flooding, erosion and sedimentation, groundwater contamination, and degradation of subterranean habitat for natural heritage resources. New karst assessment guidelines, developed by the Virginia Cave Board for land development, are available online at http://www.dcr.virginia.gov/ natural_heritage/documents/karst_assessment_guidelines.pdf.

Crozet Quad: According to the information currently in DCR DNH's files, the Mechums River - Stockton Creek SCU is located within and downstream of the project site. The Mechums River-Stockton Creek SCU has been given a biodiversity ranking of B2, which represents a site of very high significance. The natural heritage resources associated with this site are:

• Pleurobema collina, James spinymussel, G1/S1/LE/LE • aquatic natural community (NP-Rivanna Second Order Stream), G3/S3/NL/NL

The James spinymussel is currently classified as endangered by the US Fish and Wildlife Service (FWS) and the DGIF. Threats to the significant aquatic natural community and the surrounding watershed include water quality degradation related to Joel H. Peck K DEQ #16-0498 © PUE-2016-00020 (gj Page 16 Ui & point and non-point pollution, water withdrawal and introduction of non-native species. Additional information on this species and the above-referenced aquatic natural *3 community is available in DCR's attached comments. In addition, Mechum River has been designated by the DGIF as a Threatened and Endangered Species Water with the James spinymussel as the associated species.

Covesville Quad: The Rt. 708-North Fork Hardware River SCU is located within and downstream of the project site. It has a biodiversity ranking of B5, which represents a site of general biodiversity significance. The natural heritage resource associated with this site is:

• Stylurus laurae, Laura's Clubtail, G4/S2/NL/NL

Laura's clubtail (Stylurus laurae, G4/S2/NL/NL), a state rare dragonfly, ranges from Ohio south to Florida with westward records to Texas (Kondratieff, 2000). Virginia, there are records across the Piedmont and west to the Ridge and Valley region. Its habitat consists of moderated gradient streams with many shallow riffles and runs (NatureServe, 2009). Threats include activities that alter the water flow or substrate such as: impoundments, channelization, dredging, siltation, agricultural non-point pollution, and municipal and industrial pollution. In addition, timber harvest may increase siltation and cause a decrease in dissolved oxygen as canopy cover is removed and water temperature rises (NatureServe, 2009). Additional information on the dragonfly is available in DCR's attached comments.

Alberene Quad: The Rt. 708-North Fork Hardware River SCU is located within and downstream of the project site.

Simeon Quad: The Middle Fork - Cunningham Creek Stream Conservation Unit (SCU) is located within 2 miles of the project site and has a biodiversity ranking of B2, which represents a site of very high significance. Natural heritage resource associated with this site is:

• Aquatic Natural Community (NP-Rivanna Second Order Stream), G1G2/S1S2/NL/NL • Aquatic Natural Community (NP-Rivanna Third Order Stream), G1G2/S1S2/NL/NL

Threats to the significant aquatic natural community and the surrounding watershed include water quality degradation related to point and non-point pollution, water withdrawal and introduction of non-native species. Additional information on these resources is listed within DCR's attached comments.

Boyd and Palmyra Quads: The Middle Fork - Cunningham Creek SCU is located within and downstream of the project site. Joel H. Peck DEQ #16-0493 0) PUE-2016-00020 a Page 17 1/5 & 6(c) Agency Findings - Threatened and Endangered Plant and Insect Species. © DCR DNH states that the current activity will not affect any documented state-listed m m plants or insects. VDACS did not respond to DEQ's request for comments. $5

6(d) Agency Findings - Natural Area Preserves. DCR DNH states that there are no Natural Area Preserves under its jurisdiction in the project vicinity.

6(e) Agency Recommendations.

• If karst features are encountered during the project, coordinate with DCR DNH to document and minimize adverse impacts. If the project involves filling or "improvement" of sinkholes or cave openings, submit detailed location information and copies of the design specifications. In cases where sinkhole improvement is for stormwater discharge, copies of VDOT Form EQ-120 will suffice. • To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities in the Crozet and Simeon quads, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations, establishment or enhancement of riparian buffers with native plant species and maintaining natural stream flow. • Due to the legal status of the James spinymussel, DCR recommends coordination with the FWS. • To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities in the Covesville and Alberene quads, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations and that emergent vegetation adjacent to creeks be protected. • If instream work becomes necessary in the Alberene Quad, DCR recommends surveys for rare freshwater mussels and coordination with DGIF and FWS to ensure compliance with protected species legislation (see 7(c)). • To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities in the Boyd and Palmyra quads, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control and stormwater management laws and regulations. • Contact the DCR DNH to re-submit project information and a map for an update on this natural heritage information if the scope of the project changes and/or six months has passed before it is utilized.

7. Wildlife Resources. The DEQ supplement (page 8) states that Dominion will coordinate with DGIF if necessary.

7(a) Agency Jurisdiction. DGIF, as the Commonwealth's wildlife and freshwater fish management agency, exercises enforcement and regulatory jurisdiction over wildlife and freshwater fish, including state- or federally-listed endangered or threatened Joel H. Peck H» DEQ #16-0498 PUE-2016-00020 © Page 18 un A species, but excluding listed insects (Virginia Code Title 29.1). DGIF is a consulting © agency under the U.S. Fish and Wildlife Coordination Act (16 U.S.C. sections 661 et seq.) and provides environmental analysis of projects or permit applications coordinated through DEQ and several other state and federal agencies. DGIF determines likely impacts upon fish and wildlife resources and habitat, and recommends appropriate measures to avoid, reduce or compensate for those impacts.

7(b) Agency Findings. DGIF states that Sawmill Run is located within this project area and has been designated a wild brook trout stream. South Fork Moorman's River is located within this project area and has been designated a wild brown trout stream. Mechums River and Hardware River are located within the project area and have been designated a Threatened and Endangered Species Water due to the presence of federally listed endangered James spinymussels. Hardware River also has been designated a Potential Anadromous Fish Use Area.

7(c) Agency Recommendations. DGIF has the following recommendations:

• If any instream work, whether resulting in temporary or permanent impacts, is proposed within Sawmill Run or South Fork Moorman's River or their tributaries, DGIF recommends such work adhere to a time-of-year restriction from October 1 through March 31 of any year. • If any instream work, whether resulting in temporary or permanent impacts, is proposed within Mechums River, Hardware River, and/or their perennial tributaries, DGIF recommends that a mussel survey and relocation be performed from 100 meters upstream through 400 meters downstream of impact areas in such waters by a qualified, permitted biologist, preferably no more than six months prior to the start of construction. o All survey and relocation activities should adhere to the attached draft guidance. o Any relocations should be coordinated with DGIF. o No federally listed species should be relocated without first coordinating with the FWS. o DGIF recommends a time-of-year restriction on all instream work from May 15 through July 31 of any year, o Survey results should be made available to DGIF's Headquarters office in Henrico and DGIF's Forest Office. Upon review of the results, DGIF will make final recommendations regarding the protection of listed species known from the area, o All survey reports should reference the ESSLog# 36534_16-049S. o If the applicant prefers, they may provide DGIF with good, representative photographs of the impact area(s). The photographs should clearly depict the size of the stream, the substrate type, and the banks up and downstream of the site. Upon review of the photos, DGIF may be able to rule out the need for a mussel survey based on the habitat available on site. Joe! H. Peck p DEQ #16-0495 gj PUE-2016-00020 ^ Page 19 l/i

• DGIF recommends coordination with the FWS regarding federally listed species © in the area. J® • If any instream work, whether resulting in temporary or permanent impacts, is gg proposed within Hardware River, DGIF recommends that such work adhere to a time-of-year restriction from March 15 through June 30 of any year. • Conduct any in-stream activities during low or no-flow conditions, using nbn- erodible cofferdams or turbidity curtains to isolate the construction area, blocking no more than 50% of the streamflow at any given time, stockpiling excavated material in a manner that prevents reentry into the stream, restoring original streambed and streambank contours, revegetating barren areas with native vegetation, and implementing strict erosion and sediment control measures. • To minimize harm to the aquatic environment and its residents resulting from use of the Tremie method to install concrete, installation of grout bags, and traditional pouring of concrete, DGIF recommends that such activities occur only in the dry, allowing all concrete to harden and cure prior to contact with open water. Due to future maintenance costs associated with culverts, and the loss of riparian and aquatic habitat, DGIF prefers stream crossings to be constructed via clear-span bridges. However, if this is not possible, DGIF recommends countersinking any culverts below the streambed at least 6 inches, or the use of bottomless culverts, to allow passage of aquatic organisms. DGIF also recommends the installation of floodplain culverts to carry bankfull discharges. • To minimize the adverse impacts of linear utility project development on wildlife resources, DGIF offers the following general recommendations (DGIF states that it will work with the applicant to develop project-specific measures as necessary to minimize project impacts upon the Commonwealth's wildlife resources since DGIF understands that adherence to these general recommendations may be infeasible in some situations.): o Avoid and minimize impacts to undisturbed forest, wetlands and streams to the fullest extent practicable, o Maintain naturally vegetated buffers of at least 100 feet in width around all on-site wetlands and on both sides of all perennial and intermittent streams, where practicable, o Conduct significant tree removal and ground clearing activities outside of the primary songbird nesting season of March 15 through August 15. o Implement and maintain appropriate erosion and sediment controls throughout construction of the project and site restoration, o Coordinate with DGIF to develop project-specific measures if necessary.

8. Virginia Outdoors Foundation. The DEQ Supplement (page 10) states that the existing right-of-way overlaps existing Virginia Outdoors Foundation (VOF) easements.

8(a) Agency Jurisdiction. VOF was created by the General Assembly in 1966 and established in the Code of Virginia under § 10.1-1800, which states:" The Virginia Outdoors Foundation is established to promote the preservation of open-space lands and to encourage private gifts of money, securities, land or other property to preserve Joel H. Peck DEQ #16-0495 0) PUE-2016-00020 9 Page 20 1/1 the natural, scenic, historic, scientific, open-space and recreational areas of the a Commonwealth. The Virginia Outdoors Foundation is a body politic and shall be 98 governed and administered by a board of trustees composed of seven trustees from the m Commonwealth at large to be appointed by the Governor for four-year terms."

8(b) Agency Findings. VOF states that the proposed galvanized towers could have a significant visual impact along the corridor in this highly scenic area of Central Virginia. VOF holds open-space easements on 25 properties within 1.5 miles of the transmission line, a majority of which could be visually-impacted by the proposed rebuild and upgrade to galvanized steel lattice towers.

Of those 25 properties, the line physically crosses 4 properties under open-space easements within Dominion's existing right-of-way. Dominion has stated that since the proposed project is the rebuild of an existing transmission line and no additional right-of- way is required, no impact to conservation easements is expected. However, should the proposal require any additional right-of-way through a VOF easement, Dominion will need to complete a utility easement application. Staff will evaluate the request according to the specific conservation values of each easement in determining the feasibility of additional utility right-of-way, which determination will be transmitted to the board for final approval. If necessary, contact VOF to request this application. In addition, Dominion is required to obtain separate approval from the fee owner of the subject property.

In considering the impact of this proposal on conservation lands, an open-space easement is a legal interest in real property that creates a relationship between the holders of the easement and the property owner. By means of the easement, VOF has an interest in specific conservation values of the property and a legal obligation to protect these values. VOF easements provide important public benefits by protecting in perpetuity significant tracts of mostly undeveloped land which may contribute to the protection of water quality, productive soils, natural heritage resources, historic resources, and scenic viewsheds. VOF easements represent over $1 billion of public investment and fulfillment of Title XI of the Virginia Constitution and other public policies to ensure conservation of natural and cultural resources. These investments in conservation and future conservation opportunities may be jeopardized if large-scale utility development impairs the protected resources and their character-defining setting. Degradation of protected resources may result in a loss of confidence in the effectiveness of conservation easements by the public.

As mentioned above, the proposed project both crosses protected lands and will be in the viewshed of many others. VOF is concerned about the potential impact that a large- scale utility development like this may have on the scenic viewsheds and pastoral settings provided by these protected properties, especially for the driving public along Interstate 64, US Route 29, US Route 250 and State Route 20. As such, VOF requests that full consideration be given to the importance of these open-space properties and their extensive conservation values in the upgrading of this transmission corridor. Joel H. Peck DEQ #16-0495 0 PUE-2016-00020 <© Page 21 W Si a Specifically, VOF is concerned about the proposed galvanized steel lattice towers. j® Alternatives of less visual impact should be fully considered and modifications to siting, gg location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values.

While the replacement may occur within the existing right-of-way, VOF requests additional information on whether there are existing forests or vegetation that will need to be cleared, including any clearing outside of the official right-of-way in the "safety fall zone." VOF also requests additional information on whether any of the temporary construction infrastructure (roads, bridges, etc.) will need to occur on open-space easement property.

8(c) Dominion's Response. VOF raised concerns regarding vegetation removal and use of galvanized steel towers. Dominion states that the rebuilding of this line will not require additional tree clearing outside of the existing right-of-way, which varies in width. However, as required by North American Electrical Reliability Corporation, trees that are determined to be "danger trees" (any tree alive or dead that could fall within ten feet of the line) will be removed. Access to structures within the right of way will include minor improvements through the use of mats or gravel. Landowners will be notified of work on their property before the construction starts. Dominion's clearing methods are described in greater detail in Section II.A.5 of the Appendix (page 38) and Section 2.K of the DEQ Supplement (pages 10-11) filed with the Application.

Dominion has proposed to use its typical transmission line materials and structures to rebuild this line. The existing steel lattice towers (brown structures) proved to be inferior and degraded greatly over time. Dominion now uses galvanized lattice towers for all 500 kV lines. The galvanized steel is used throughout the industry and has proven to be the best type of finish for lattice towers. Depending on environmental conditions, galvanized steel lattice structures take between 24 and 48 months to achieve the typical dullness that is seen on older galvanized steel structures. Using galvanized steel towers provides the greatest protection against the elements and ensures that structures can meet the 40-50 year lifespan with minimal maintenance. Dominion does not believe that the additional cost and potential decrement in structural integrity posed by the use of non- reflecting or de-glared conductors and dulled steel for structures, as requested by VOF, is appropriate.

8(d) VOF's Response. VOF would like to reiterate the points made in its original letter and specifically the following points:

VOF is concerned about the proposed galvanized steel lattice towers. Alternatives of less visual impact should be fully considered and modifications to siting, location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values. Joel H. Peck DEQ #16-0495 PUE-2016-00020 m Page 22 1/1

If the SCC certificate is issued, the permit should require implementation of all industry <9 9 best practices, including, but not limited to (1) minimal removal of vegetation through W use of a clearing plan and (2) use of non-reflecting or de-glared conductors and dulled m steel for towers and structures.

VOF appreciates Dominion Virginia Power's response regarding the removal of vegetation and have no further comments on that. However, with regard to VOF's request for consideration of the use of low reflective visual mitigations, VOF has worked with other utilities, specifically the Appalachian Power Company (ACP), that have implemented these visual mitigations in the construction of electric transmission lines. ACP has used a darkened or low-reflective treatment applied to the finish of galvanized steel lattice towers to reduce the visual presence of the structures in scenic areas. The company also has applied a non-specular finish to reduce glare and mitigate visual impacts to the conductors. These significant and proven visual mitigations demonstrate that it is possible to make changes to the design and materials of electric transmission lines in some cases.

VOF hopes to continue to work with Dominion Virginia Power in a collaborative way to ensure that the Commonwealth's investments in the protection of open space are not jeopardized in any way.

8(e) Agency Recommendations.

• VOF recommends that if the SCC certificate is issued, it should require implementation of all industry best practices, including, but not limited to (1) minimal removal of vegetation through use of a clearing plan and (2) use of non- reflecting or de-glared conductors and dulled steel for towers and structures. • VOF recommends that Dominion Virginia Power consider any measures that might minimize the visual impacts to the important scenic and cultural resources of this region. • VOF recommends that Dominion and the SCC give full consideration to the importance of these open space properties and their extensive conservation values in the upgrading of this transmission corridor.

8(f) Requirements. Should the proposal require any additional right-of-way through a VOF easement, Dominion will need to complete a utility easement application. Virginia Code §10.1-1704 (1950), as amended, requires that land designated as open space shall not be converted or diverted from open-space land use unless the public body that designated the land as open-space finds that the conversion or diversion meets several criteria.

9. Recreational Resources. According to the DEO Supplement (page 10), the project is expected to have minimal permanent impacts on recreational resources. Joel H. Peck DEQ #16-0495 PUE-2016-00020 Page 23

9(a) Agency Jurisdiction. The DCR Division of Planning and Recreational Resources (DPRR) administers the Virginia Scenic Rivers (Virginia Code § 10.1-200), Virginia Byways (Virginia Code §33.2-405 through 33.2-408), and state trails programs (Virginia Code §10.1-204) and is responsible for developing the Virginia Outdoors Plan (VOP), the state's comprehensive outdoor recreation and open space plan (Virginia Code §10.1-200). The VOP recognizes the importance of scenery to Virginians and many of the top ten activities are water based.

9(b) Agency Findings. The DCR DPRR states that the proposed project impacts several scenic resources. In Albemarle County, the project crosses the potentially scenic Mechums River and Scenic Byway Route 20. Further, the project route appears to cross federal lands and two nationally significant resources: the Appalachian Trail and the Blue Ridge Parkway.

9(c) Agency Recommendations. DCR DPRR has the following recommendations:

• Cross Mechums River and Scenic Byway Route 20 in as a perpendicular manner as possible and restore all land disturbance using native plant species. • Coordinate with federal partners and managing entities of the Appalachian Trail and the Blue Ridge Parkway.

10. Historic and Archaeological Resources. According to the DEQ supplement (pages 8-10), there are archaeological and historic resources in the project area.

10(a) Agency Jurisdiction. The Department of Historic Resources (DHR) conducts reviews of projects to determine their effect on historic structures or cultural resources under its jurisdiction. DHR, as the designated State's Historic Preservation Office, ensures that federal actions comply with Section 106 of the National Historic Preservation Act of 1962 (NHPA), as amended, and its implementing regulation at 36 CFR Part 800. The NHPA requires federal agencies to consider the effects of federal projects on properties that are listed or eligible for listing on the National Register of Historic Places. Section 106 also applies if there are any federal involvements, such as licenses, permits, approvals or funding. DHR also provides comments to DEQ through the state environmental impact report review process.

10(b) Agency Comments. DHR has not been notified by any federal agency of its involvement in this project; however, DHR reserves the right to provide additional comments pursuant to the National Historic Preservation Act, if applicable. Dominion's pre-application analysis, included in the SCC application as DEQ Supplement, Attachment 2.H.2, considers the potential impact of the proposed project on recorded archaeological sites and on known historic architectural properties listed or previously determined eligible for listing in the Virginia Landmarks Register (VLR) and the National Register of Historic Places (NRHP) within a tiered study area. DHR's comments on the pre-application analyses are provided below (see attached letter for explanation of impact descriptions): Joel H. Peck DEQ # 16-049S m PUE-2016-00020 Page 24 1/1 Xb a 10(c) Agency Findings. To summarize, the pre-application analysis identified nine ^ VLR/NRHP-listed landmarks and historic districts, including one National Historic ©3 Landmark, and one VLR/NRHP-eligible historic district within the tiered study area. Based upon a review of the information provided, DHR concurs that four architectural resources will have no impacts, four resources will have minimal impacts, and one resource will have moderate impacts from the proposed 500 kV rebuild. DHR does not concur that there will be minimal impacts to the Greenwood-Afton Rural Historic District, and recommends that the impacts will be moderate. See the attached table for details regarding these recommendations. Ten previously identified archaeological sites are located within or immediately adjacent to the right-of-way. One has been determined potentially eligible for VLR/NRHP listing and the remaining ones have not been evaluated. VLR/NRHP eligibility of these sites and potential impacts of the project should be considered as part of the additional studies recommended below. Impacts to unrecorded or unevaluated historic resources have not yet been considered.

10(d) Agency Recommendations. Consistent with DHR's Guidelines and the consultant's findings, DHR has the following recommendations:

• Conduct comprehensive archaeological and architectural surveys in accordance with DHR guidelines by qualified professionals prior to construction of any SCC- approved alternative. Areas previously subjected to archaeological survey do not need to be resurveyed, but identified sites must be evaluated. • Evaluate all identified resources for listing in the VLR and NRHP, including previously inaccessible properties. • Assess potential direct and indirect impacts to all eligible and listed resources of the VLR and NRHP. • Avoid, minimize and/or mitigate moderate to severe impacts to eligible and listed resources of the VLR and NRHP in consultation with DHR and other stakeholders.

10(e) Requirement. If there is any federal involvement, Dominion should coordinate the project or any portion thereof with the responsible federal agency and DHR to ensure compliance with Section 106 of the National Historic Preservation Act, as amended, and its implementing regulations at 36 CFR 800.

11. Transportation Impacts. The DEQ Supplement (page 12) states that the right-of- way crosses 59 public and private roads.

11(a) Agency Jurisdiction. The Virginia Department of Transportation (VDOT) provides comments pertaining to potential impacts to existing and future transportation systems.

11(b) Agency Findings. The VDOT Staunton District and Culpeper District have reviewed the SCC application. All work associated with the project will occur within the Joel H. Peck p DEQ #16-0493 & PUE-2016-00020 gj Page 25 tn existing transmission line right-of-way with the exception of VDOT road crossings over © secondary and primary roads, and Interstate 64. Based on the alignment of the existing right-of-way, the project will consist of an approximately 4.2 mile segment in Augusta County that will cross the following state maintained public roadways: Route 611, Dooms Crossing Road and Route 622, Calf Mountain Road. In Albemarle County there will be numerous state secondary road crossings along with primary routes to include Routes 20, 29 and Route 250. There will be some secondary roads impacted with road crossings in Fluvanna County as well. VDOT states that permits will be issued for each location separately and can be inspected and released as each of the sections are completed.

11(c) Agency Recommendations. From a non-transportation standpoint, VDOT recommends consideration and discussions with all appropriate agencies and localities regarding the rebuild project of Line #534, especially given the alignment of this project crossing Shenandoah National Park and the Appalachian Trail Corridor.

11(d) Requirements.

• Any required work that will encroach into the right-or-way or easements of state maintained roadways or impacts vehicular traffic operations will be required to comply with VDOT's Land Use Permit Regulations (24 VAC 30-151) and work areas will comply with the 2011 Virginia Work Area Protection Manual's Latest Edition. • VDOT states that it must review and approve the following: o Construction entrance locations for sight distance and entrance design; o Advance construction entrance signage to be placed prior to entrance on both sides; and o Work zone plans and permits for all crossings to be submitted and reviewed prior to work starting, allowing 30 days for review and approval of crossings for Routes lnterstate-64 and 250.

12. Aviation Impacts. The DEQ Supplement (page 13) indicates that impacts to airports were considered.

12(a) Agency Jurisdiction. The Virginia Department of Aviation (DOAV) is a state agency that plans for the development of the state aviation system; promotes aviation; grants aircraft and airports licenses; and provides financial and technical assistance to cities, towns, counties and other governmental subdivisions for the planning, development, construction and operation of airports, and other aviation facilities.

12(b) Agency Finding. The DOAV states that the closest public-use airport to the proposed project location is the Eagle's Nest Airport near Waynesboro. Joel H. Peck P DEQ #16-0493 PUE-2016-00020 0 Page 26 C- & 12(c) Requirements. To ensure that the proposed facility would not create a hazard to ® air navigation for the airport, given that some of the new structures are of a greater ^ height, the applicant should confirm with the FAA that Part 77 safety areas, especially the horizontal surface, are not penetrated through the filing of Form 7460-1 with the FAA's Washington Airports District Office.

12(d) Agency Recommendations.

• The design of the transmission line and station rebuild must prevent interference with pilots' safe ingress and egress at the airport. • Operational activities along the transmission line should not pose a hazard or impediment to pilots using the airport. Such hazards or impediments include interference with navigation and communication equipment, interference with existing and planned approach procedures for all aircraft published for or by the airport, and glare from building materials.

13. Public Water Supply. The DEQ supplement does not address water supply sources.

13(a) Agency Jurisdiction. The Virginia Department of Health (VDH) Office of Drinking Water (ODW) reviews projects for the potential to impact public drinking water sources (groundwater wells, springs and surface water intakes). VDH administers both federal and state laws governing waterworks operation.

13(b) Agency Findings. VDH ODW states that there may be impacts to public drinking water sources due to this project if the mitigation efforts outlined below are not implemented. The following public groundwater wells are located within a 1-mile radius of the project site (wells within a 1,000-foot radius are formatted in bold):

PWSID District CNYCTY SYSNAME FACNAME 2003054 DISTRICT 10 ALBEMARLE ACSA RED HILL WELL #5 2003177 DISTRICT 10 ALBEMARLE CHARLOTTESVILLE KOA WELL 2003850 DISTRICT CORVILLE FARM 10 ALBEMARLE SUBDIVISION WELL C 2003665 DISTRICT MISTY MOUNTAIN CAMP DEEP 10 ALBEMARLE RESORT WELL 2003475 DISTRICT 10 ALBEMARLE MILLER SCHOOL WELL 2 2003475 DISTRICT 10 ALBEMARLE MILLER SCHOOL WELL 3 Joel H. Peck P DEQ #16-0495 m PUE-2016-00020 Page 27 VI & 2003880 DISTRICT WALTON MIDDLE 10 ALBEMARLE SCHOOL WL 2065783 DISTRICT @8 10 ALBEMARLE TENASKA WELL 2 2065783 DISTRICT 10 ALBEMARLE TENASKA WELL 1

The following surface water intakes are ocated within a 5-mile radius of the project site PWSID SYSNAME FACNAME 2003600 OBSERVOIR WTP SUGAR HOLLOW RESERVOIR 2003250 CROZET WTP BEAVER CREEK RESERVOIR 2065480 LAKE MONTICELLO

The project is within the watershed of the following public surface water sources (intakes where the project falls within 5 miles into their watershed are formatted in bold): PWSID SYSNAME FACNAME 2003250 CROZET WTP BEAVER CREEK RESERVOIR 2003600 OBSERVOIR WTP SUGAR HOLLOW RESERVOIR 2065480 LAKE MOTICELLO RIVANNA RIVER 2003600 OBSERVATORY WTP RAGGED MOUNTAIN RESERVOIR 2003675 SCOTTSVILLE WTP TOTIER RESERVOIR INTAKE 2003675 SCOTTSVILLE WTP TOTIER CREEK INTAKE HENRICO COUNTY WATER 4087125 SYSTEM HENRICO RAW WATER INTAKE 2003725 SOUTH RIVANNA WTP SOUTH FORK RIVANNA RESERVOIR 4075735 CORRECTIONAL JAMES RIVER INTAKE 4761011 RICHMOND, CITY OF RAW WATER INTAKE VIRGINIA-AMERICAN 3670800 WATER CO. APPOMATTOX RIVER

13(c) Agency Recommendations. VDH ODW has the following recommendations:

• Implement best management practices, including erosion and sedimentation controls as well as spill prevention controls and countermeasures, on the project site. • Field mark and protect well(s) within the 1,000-foot radius of the project site from accidental damage due to construction activities. Joel H. Peck p DEQ #16-0495 ® PUE-2016-00020 © Page 28 l/i £ • Ensure that care is taken while transporting materials in and out of the project <0 site to prevent impacts to surface water intakes within 5 miles. ® 0 14. Pollution Prevention. DEQ advocates that principles of pollution prevention be used in all construction projects. Effective siting, planning and on-site best management practices will help to ensure that environmental impacts are minimized. Pollution prevention techniques also include decisions related to construction materials, design and operational procedures that facilitate the reduction of wastes at the source. We have several recommendations regarding pollution prevention:

• Consider development of an effective Environmental Management System (EMS). An effective EMS will ensure that the proposed project is committed to minimizing its environmental impacts, setting environmental goals and achieving improvements in its environmental performance. DEQ offers EMS development assistance and it recognizes facilities with effective Environmental Management Systems through its Virginia Environmental Excellence Program. • Consider environmental attributes when purchasing materials. For example, the extent of recycled material content, toxicity level and amount of packaging should be considered and can be specified in purchasing contracts. • Consider contractors' commitment to the environment (such as an EMS) when choosing contractors. Specifications regarding raw materials and construction practices can be included in contract documents and requests for proposals.

DEQ's Office of Pollution Prevention provides information and technical assistance relating to pollution prevention techniques and EMS. If interested, please contact DEQ (Meghann Quihn at 804-698-4021).

15. Pesticides and Herbicides. In general, when pesticides or herbicides must be used, their use should be strictly in accordance with manufacturers' recommendations. In addition, we recommend that Dominion use the least toxic pesticides or herbicides effective in controlling the target species to the extent feasible. For more information on pesticide or herbicide use, contact VDACS at (804) 786-3798.

16. Local Participation. As customary, DEQ invited the affected localities and planning district commissions to participate in the Commonwealth's environmental review of this proposal. This approach is consistent with the SCC Law (Virginia Code § 56-46.1 A.), which directs the SCC to consider local comprehensive plans which have been adopted pursuant to Virginia Code § 15.2-2223 et seq.

16(a) Regional Findings. The Thomas Jefferson Planning District Commission (PDC) has no environmental issues or concerns with the rebuild project as proposed. However, providing broadband supply lines or antennas into the rural areas where this transmission line is currently located would provide an opportunity to rural areas with services that are currently unavailable and would do so without additional structures having to be constructed that could cause unnecessary environmental impacts. Both Joel H. Peck K> DEQ #16-0493 gj) PUE-2016-00020 d Page 29 m A Albemarle and Fluvanna counties are currently exploring ways to reach underserved © rural areas of their counties with essential broadband utility service, and a cooperative use of existing structures could provide this means in an economical and environmentally positive manner. The Central Shenandoah Planning District Commission has no comments.

16(b) Regional Recommendations. The Thomas Jefferson PDC recommends the .consideration of designing structures that will allow additional lease use for broadband internet transmission and/or service uses.

16(c) Local Findings. Augusta County states that it is included in the service area upgrade for the proposed rebuild project. The county also has received a Virginia Telecommunication Planning Initiative (VATPI) Grant to develop a plan for improving and expanding internet service in the area. The county's telecommunications plan consultant is tasked with providing recommendations and network alternatives that are feasible and achievable for the community. Part of this task is to identify existing infrastructure and providers that may consider public-private partnerships to expand Internet service into the county. The Cunningham-Dooms Transmission Line Rebuild project will be able to assist in this task by providing structures that will allow additional lease use for broadband internet transmission and/or service uses. Multiple uses of the same easement will allow for less environmental impact on the rural area. Joel H. Peck p DEQ #16-0495 PUE-2016-00020 Page 30 ui

REGULATORY AND COORDINATION NEEDS Q G) M 1. Water Quality and Wetlands. As stated in the Environmental Impacts and

2. Subaqueous Lands Impacts. Pursuant to section 28.2-1204 of the Code of Virginia, the VMRC has jurisdiction over any encroachments in, on or over any state- owned rivers, streams or creeks in the Commonwealth. Contact VMRC (Randy Owen at 757-247-2251 or [email protected]) regarding the submittal of a JPA.

3. Erosion and Sediment Control. Transmission line construction must comply with Dominion's DEQ-approved annual specifications. Dominion must contact [email protected] two weeks prior to land disturbance. Dominion must have a certified Responsible Land Disturber in charge of and responsible for carrying out the project-specific erosion and sediment control plan and the land-disturbing activity. Questions regarding annual erosion and sediment control specifications should be directed to DEQ (Larry Gavan at [email protected] or 804-698- 4040) (Reference: VESCR §9VAC25-840-30, §9VAC25-840-40). Buildings, facilities and other structures not covered under § 62.1-44.15:55 must comply with the requirements of the appropriate local erosion and sediment control and stormwater program. Dominion must contact officials with the appropriate locality to determine local requirements.

4. VSMP Stormwater Management General Permit. For projects involving land- disturbing activities equal to or greater than 1 acre, Dominion is required to apply to DEQ under the Virginia Stormwater Management Program (VSMP) General Permit for Discharges of Stormwater from Construction Activities and develop a project specific stormwater pollution prevention plan (SWPPP). Construction activities requiring registration also includes the land disturbance of less than 1 acre of total land area that is part of a larger common plan of development or sale, if the larger common plan of development will ultimately disturb equal to or greater than 1 acre. The SWPPP must be prepared prior to submission of the registration statement for coverage under the general permit, and the SWPPP must address water quality and quantity in accordance VSMP Permit Regulations (VSWML §62.1-44.15:24 et seq.; VSMP Permit Regulations 9VAC25-870 et seq.). Specific questions regarding the VSMP General Permit for Construction Activities requirements should be directed to DEQ (Holly Sepety at 804- 698-4039 or [email protected]).

5. Air Quality Regulation. Construction and operation of the transmission lines are subject to air pollution control regulations administered by DEQ. The following sections of Virginia Administrative Code may be applicable: Joel H. Peck DEQ #16-0495 PUE-2016-00020 a Page 31 m £ a • 9VAC5-80, Article 6, Permits for New and Modified Sources for fuel-burning a w equipment; • 9VAC5-50-60 et seq. governing fugitive dust emissions; and • 9VAC5-130 et seq. for open burning.

Contact DEQ VRO (Janardan Pandey at 540-574-7817 or Janardan.Pandey@deq. virginia.gov) for additional information and prior to operation of fuel-burning or other air- pollution-emitting equipment.

6. Solid Waste and Hazardous Substances.

6(a) Solid and Hazardous Waste. Contaminated soil, all solid waste, hazardous waste, and hazardous materials must be managed in accordance with all applicable federal, state and local environmental regulations. Applicable state regulations may include:

• Virginia Waste Management Act (Code of Virginia section 10.1-1400 et seq.); • Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC20-60); • Virginia Solid Waste Management Regulations (VSWMR) (9VAC20-81); and • Virginia Regulations for the Transportation of Hazardous Materials (9VAC20- 110). Applicable federal regulations may include:

• Resource Conservation and Recovery Act (RCRA) (42 U.S.C. section 6901 et seq.), and the applicable regulations contained in Title 40 of the Code of Federal > Regulations; and • U.S. Department of Transportation Rules for Transportation of Hazardous Materials, 49 CFR Parts 107, 171.1-172.558. Contact DEQ VRO (Graham Simmerman at 540-574-7865 or Graham.Simmerman @deq.virginia.gov) for additional information. .

6(b) Asbestos-Containing Material. If applicable, it is the responsibility of the owner or operator of a demolition activity, prior to the commencement of the demolition, to thoroughly inspect the affected part of the facility where the operation will occur for the presence of asbestos, including Category I and Category II non-friable asbestos- containing material. Upon classification as friable or non-friable, all asbestos-containing material shall be disposed of in accordance with the Virginia Solid Waste Management Regulations (9VAC 20-81-620) and transported in accordance with the Virginia regulations governing Transportation of Hazardous Materials (9VAC20-110-10 et seq.). Contact DEQ DLPR (Katy Dacey at 804-698-4274 or Katy [email protected]) for additional information and the Department of Labor and Industry (804-371-2327). Joel H. Peck p DEQ #16-0495 & PUE-2016-00020 Page 32 i/J

6(c) Lead-Based Paint. If applicable, this project must comply with the U.S. <09 Department of Labor Occupational Safety and Health Administration (OSHA) ©

7. Natural Heritage Resources.

• Coordinate with DCR DNH (Wil Orndorff at 540-230-5960 or [email protected]) regarding comments and recommendations on karst resources. • Contact DCR DNH (Rene' Hypes at 804-371-2708 or Rene.Hypes @dcr.Virginia.gov) for additional information on updates to the Biotics Data System as necessary.

8. Wildlife Resources and Protected Species.

• Coordinate any species relocations with DGIF (Brian Watson, DGIF Region II Aquatic Resources Biologist at 434-525-7522) as necessary. • Coordinate with the FWS (804-693-6694) prior to relocating federally listed species as necessary. • Coordinate with the FWS (Cindy Schulz at 804-824-2426 or [email protected]) due to the legal status of the James spinymussel as appropriate. • Contact DGIF Headquarters (Amy Ewing at [email protected]) and the DGIF Forest Office (Brian Watson at [email protected]) regarding mussel survey results. • For additional information and coordination as necessary, contact DGIF (Amy Ewing at 804-367-2211 [email protected]) about its recommendations.

9. Open Space. Coordinate with the VOF (Martha Little at 804-577-3337 or [email protected]) for additional information about its recommendations as necessary.

10. Recreational Resources. Coordinate with DCR DPRR (Tom Smith, Deputy Director, at [email protected]) regarding its recommendations.

11. Historic and Archaeological Resources. If applicable, Dominion should coordinate the project with the responsible federal agency and DHR to ensure compliance with Section 106 of the National Historic Preservation Act, as amended, and its implementing regulations at 36 CFR 800. Contact DHR (Roger Kirchen at 804-367- 2323, extension 153 or [email protected]) regarding its recommendations and coordination as necessary. Joel H. Peck p DEQ #16-0498 © PUE-2016-00020 Page 33 lm & 12. Transportation Impacts. Contact VDOT (Dennis Seale at 434-531-2877) for <© additional information about its comments, recommendations and requirements as a 60 necessary. ©0

13. Aviation Impacts. Contact the FAA Washington Airports District Office (703-661- 1354) as necessary for compliance with federal aviation requirements and DOAV (Susan Simmers at [email protected]) for additional information if necessary.

14. Water Supply. Contact VDH ODW (Roy Soto at [email protected]) for additional information about its recommendations.

15. Local Concerns. Coordinate with the Thomas Jefferson Planning District Commission (Charles Boyles, Executive Director, at 434-979-7310) for additional information about its recommendation. p

Wellman, Julia (DEQ) m Ui From: Ewing, Amy (DGIF) & Sent: Tuesday, April 19, 2016 1:27 PM a To: Wellman, Julia (DEQ) <15 Cc: nhreview (DCR); Watson, Susan (DGIF); Bugas, Paul (DGIF) m Subject: ESSLog# 36534_16-049S_Cunningham to Dooms transmission line rebuild w Attachments: MusselGuidelines_Jun22_2015_WatFinaldraft.pdf

Sawmill Run is located within this project area and has been designated a wild brook trout stream. If any instream work, whether resulting in temporary or permanent impacts, is proposed within Sawmill Run or its tributaries, we recommend such work adhere to a time of year restriction from October 1 through March 31 of any year.

South Fork Moorman's River is located within this project area and has been designated a wild brown trout stream. If any instream work, whether resulting in temporary or permanent impacts, is proposed within Sawmill Run or its tributaries, we recommend such work adhere to a time of year restriction from October 1 through March 31 of any year.

Meechums River and Hardware River are located within the project area and have been designated a Threatened and Endangered Species Water due to the presence of federally Endangered James spinymussels. If any instream work, whether resulting in temporary or permanent impacts, is proposed within Meechums River, Hardware River, and/or their perennial tributaries, we recommend that a mussel survey and relocation be performed from 100 meters upstream through 400 meters downstream of impact areas in such waters. This survey should be performed by a qualified, permitted biologist, preferably no more than six months prior to the start of construction. All survey and relocation activities should adhere to the attached draft guidance. Any relocations should be coordinated with Brian Watson, VDGIF Region II Aquatic Resources Biologist (434-525-7522), and no federally listed species should be relocated without first coordinating with the USFWS (804-693-6694). In addition, we recommend a time of year restriction on all instream work from May 15 through July 31 of any year. Survey results should be made available to Amy Ewing in VDGIF's Headquarters office in Henrico and Brian Watson in VDGIF's Forest Office. Upon review of the results, we will make final recommendations regarding the protection of listed species known from the area. All survey reports should reference the ESSLog# displayed in the subject line of this email.

If the applicant prefers, they may provide us with good, representative photographs of the impact area(s) for our review. The photos should clearly depict the size of the stream, the substrate type, and the banks up and downstream of the site. Upon review of the photos, we may be able to rule out the need for a mussel survey based on the habitat available on site.

Further, we recommend coordination with the USFWS regarding federally listed species in the area.

Hardware River also has been designated a Potential Anadromous Fish Use Area. If any instream work, whether resulting in temporary or permanent impacts, is proposed within Hardware River, we recommend that such work adhere to a time of year restriction from March 15 through June 30 of any year.

We recommend conducting any in-stream activities during low or no-flow conditions, using non-erodible cofferdams or turbidity curtains to isolate the construction area, blocking no more than 50% of the streamflow at any given time, stockpiling excavated material in a manner that prevents reentry into the stream, restoring original streambed and streambank contours, revegetating barren areas with native vegetation, and implementing strict erosion and sediment control measures. To minimize harm to the aquatic environment and its residents resulting from use of the Tremie method to install concrete, installation of grout bags, and traditional pouring of concrete, we recommend that such activities occur only in the dry, allowing all concrete to harden and cure prior to contact with open water. Due to future maintenance costs associated with culverts, and the loss of riparian and aquatic habitat, we prefer stream crossings to be constructed via clear-span bridges. However, if this is not possible, we recommend countersinking any culverts below the streambed at least 6 inches, or the use of bottomless culverts, to allow passage of aquatic organisms. We also recommend the installation of floodplain culverts to carry bankfull discharges.

To minimize the adverse impacts of linear utility project development on wildlife resources, we offer the following general recommendations: avoid and minimize impacts to undisturbed forest, wetlands, and streams to the fullest extent practicable; maintain naturally vegetated buffers of at least 100 feet in width around wetlands and on both sides of perennial and intermittent streams, where practicable; conduct significant tree removal and ground clearing activities outside of the primary songbird nesting season of March 15 through August 15; and, implement and maintain appropriate

i erosion and sediment controls throughout project construction and site restoration. We understand that adherence to these general recommendations may be infeasible in some situations. We are happy to work with the„applicant to . ^ develop project-specific measures as necessary to minimize project impacts upon the Commonwealth's wildlife ^ resources. ^ <3 This project is located within 2 miles of a documented occurrence of a state or federal threatened or endangered plant or © insect species and/or other Natural Heritage coordination species. Therefore, we recommend coordination with VDCR- @0 DNH regarding the protection of these resources. SO

Thanks, Amy Amy M. Ewing Environmental Services Biologist/FWIS Biologist Supervisor Chair, Team WILD (Work, Innovate, Lead and Develop) VA Department of Game and Inland Fisheries 7870 Villa Park Dr., Suite 400, PO Box 90778, Henrico, VA 23228 804-367-2211© www.dgif.virginia.g6v

Please consider the environment before printing this email. '

2 J**

^ Dopartment ol Gfimt i & CA Inland Fbhadn/ m FRESHWATER MUSSEL GUIDELINES FOR VIRGINIA 159

Virginia Field Office Virginia Dept. of Game and Inland Fisheries U.S. Fish and Wildlife Service 4010 West Broad Street 6669 Short Lane P.O. Box 11104 Gloucester, VA 23061 Richmond, VA 23230 804-693-6694 804-367-1000

Last Updated: 6-22-15 DRAFT LIST OF ENCLOSURES

1 - Federal and State-Listed Species in Virginia 2 - Mussel Survey and Relocation Guidelines in Virginia 3 - Surveyor List for Atlantic Slope Mussels in Virginia 4 - Surveyor List for Upper Tennessee River Basin Mussels in Virginia 5 - Time of Year Restrictions (See Freshwater Mollusks) 6 - Map of Federally-Designated Critical Habitat for Mussels in Virginia

INTRODUCTION

These guidelines are for project applicants and consultants planning certain activities that will impact rivers, streams, creeks, or other waterways in Virginia. The guidelines provide recommendations for conducting freshwater mussel surveys and relocations for small construction projects of short duration involving non-point pollution sources and affecting no more than 100 linear feet of waterway. Larger projects that impact waters containing State or federally listed mussels may require additional coordination or permits from the Virginia Department of Game and Inland Fisheries (VDGIF) and/or the U.S. Fish and Wildlife Service (FWS). Coordination with these agencies should always be initiated to ensure compliance with Federal and State laws.

FWS is responsible for the conservation and management offederally listed freshwater mussel species. VDGIF is responsible for the conservation and management of all freshwater mussel species throughout Virginia. If it is known that federally listed species or critical habitat (Enclosure 6) are not present within a two-mile radius of a given site, coordination with VDGIF, but not FWS, is still necessary.

GENERAL LIFE HISTORY

Freshwater mussels are often prominent in benthic stream communities where, for the most part, they are sedentary filter-feeders consuming a major portion of the suspended particulate matter. Therefore, mussel beds act as biological filters by removing inorganic and organic material from the water column while improving water quahty downstream. Individuals are typically long- lived, with particular species living for more than 50 years, while some individuals may live for more than 130 years. Because these mussels are long-lived, sedentary filter-feeders, they are prominent indicators of water quahty. Freshwater mussels also serve as an important dietary component to a variety of animals, including muskrats, otters, raccoons, and some fishes.

During spawning, male mussels release sperm into the water column that females take in through their gills. The resulting larvae (known as glochidia) may be released by the female into the water column or packaged to attract fish. These larvae must attach to a fish host to survive. While attached to the gills of the fish host, development of the glochidia begins. Once metamorphosis is complete, the juvenile mussel drops off the fish host and continues to develop on the stream bottom.

Freshwater mussels are generally divided into two reproductive categories known as short-term (tachytictic) or long-term brooders (bradytictic). Short-term brooders usually spawn and release glochidia during May through July in Virginia. Long-term brooders usually spawn from August through September and release glochidia the following April through June.

SURVEYS AND RELOCATIONS

Enclosure 1 is a list of federally endangered, threatened, and candidate mussels and State endangered and threatened mussels. If a project occurs in an area that may contain suitable habitat for one of these species, FWS and/or VDGIF may recommend a survey. To determine which waterways may contain suitable habitat for State or federally-listed species, contact VDGIF for guidance (804-367-2211 or 2733). Apphcants should contact FWS and VDGIF early in the planning process to determine whether federally or State-hsted species or critical habitat may be impacted by the project. The effects of a project may include direct impacts from construction activities as well as downstream impacts from sedimentation and effluent discharges. If mussels were found during any previous survey/s, however old, coordination with VDGIF and FWS (where applicable) will be required. Surveys where mussels are not found (negative surveys) are typically valid for two years, after which another survey should be performed. Guidelines for freshwater mussel surveys and relocations are found in Enclosure 2. Surveyor lists are included in Enclosures 3 and 4. If listed mussels are found in or downstream of a project area, VDGIF and/or FWS are likely to recommend time of year or other restrictions to reduce impact to the mussels. Time of year restrictions are listed in Enclosure 5. If FWS determines that the project "may affect" a federally listed species or critical habitat, consultation with FWS will be required.

LAWS AND REGULATIONS PROTECTING MUSSELS

Federal Endangered Species Act (ESA) (87 Stat. 884; 16 U.S.C. 1531 et seq.; 50 CFRPart 17) Section 7(a)(2) requires Federal agencies to ensure that any action they authorize, fiind, or carry out is not likely'to jeopardize the continued existence of any federally listed threatened or endangered species, or result in the destruction or adverse modification of critical habitat. The regulations implementing this Act (50 CFR 402) require the Federal agency to review its actions at the earliest possible time to determine whether its actions may affect listed species or critical habitat. If a Federal agency determines that its action "may affect" a listed threatened or endangered species or critical habitat, the agency is required to consult with FWS regarding the degree of impact and measures available to avoid or minimize the adverse effects.

Section 9 of the ESA makes it illegal for any person subject to the jurisdiction of the United States to "take" any federally listed endangered or threatened species of fish or wildlife without a special exemption. "Person" is defined under the ESA to include individuals, corporations, partnerships, trusts, associations, or any other private entity; local, State, and Federal agencies; or any other entity subject to the jurisdiction of the United States. Under the ESA, "take" means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, collect, or to attempt to engage in any such conduct. Harm is further defined to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing essential behavior patterns such as breeding, feeding, or sheltering. Harass is defined as actions that create the likelihood of injury to listed species to such an extent as to significantly dismpt normal behavior patterns which include, but are not limited to, breeding, feeding, or sheltering.

Section 10 establishes an incidental take permit provision for private entities that includes the development of habitat conservation plans. This provision authorizes FWS, under some circumstances, to permit the taking of federally listed fish and wildlife if such taking is "incidental to, and not the purpose of carrying out otherwise lawful activities." This process is also intended to be used to reduce conflicts between fisted species and private development and to provide a fiamework that would encourage "creative partnerships" between the private sector and local, state, and Federal agencies in the interest of endangered and threatened species and habitat conservation. When approved by FWS, this regulatory procedure results in the issuance of a permit authorizing incidental take, provided such take is mitigated by appropriate conservation measures for habitat maintenance, enhancement, and protection, coincident with development.

Virginia Endangered Species Act (29.1-563 - 29.1-570) - This law provides that VDGIF is the state regulatory authority over federally or state fisted endangered or threatened fish and wildlife in the Commonwealth, definingyis/z or wildlife as "... any member of the animal kingdom, vertebrate or invertebrate, except for the class Insecta, and includes any part, products, egg, or the dead body or parts thereof" It prohibits the taking, transportation, processing, sale, or offer for sale within the Commonwealth of any fish or wildlife fisted as a federally endangered or threatened species, except as permitted by the Board of Game and Inland Fisheries for zoological, educational, scientific, or captive propagation for preservation purposes. State-listed species are provided the same protection per VDGIF Regulation 4 VAC 15-20-130.

The law further authorizes the Board of the Virginia Department of Game and Inland Fisheries to adopt the Federal fist of endangered and threatened species, to declare by regulation that species not fisted by the Federal government are endangered or threatened in Virginia, and to prohibit by regulation the taking, transportation, processing, sale, or offer for sale of those species. Implementing regulations pursuant to this authority (4 VAC 15-20-130 through 140) further define "take" and other terms similarly to the Federal ESA.

Federal Endangered Species Act Cooperative Agreement - Federally listed species are also protected under VDGIF jurisdiction via a cooperative agreement signed in 1976 with FWS pursuant to Section 6 of the ESA. This Cooperative Agreement recognizes VDGIF as the Virginia agency with regulatory and management authority in Virginia over federally listed or threatened animals, excluding insects, and provides for Federal/State cooperation regarding the protection and management of those species. m m & m Enclosure 1: Federal and State Listed Mussel Species in Virginia m

U.S. Fish and Wildlife Service: Environmental Conservation Online System (ECOS) m ('http://ecos.fws. gov/ecp/1

Virginia Department of Game and Inland Fisheries: Special Legal Status Faunal Species in Virginia fhttp://www.dgif. virginia.gov/wildhfe/virginiatescspecies.pdf)

Enclosure 2: Mussel Survey and Relocation Guidelines in Virginia

There are four general assessment/survey types including:

A. Land-based review - land-based site visit used to determine whether a water-based survey (site assessment, abbreviated, or full survey) is warranted. During a land-based review, the surveyor should look for obvious signs that would negate the need for additional, water-based surveys. For example, if it can be determined that the water body is non-perennial and/or contains no potential mussel habitat, it is unlikely that additional surveys would be needed or recommended by VDGIF or FWS. If it is determined that suitable habitat is present, the appropriate survey will be recommended. Photographs of the project site clearly showing instream habitat conditions, as well as a thorough site description, should be sent to VDGIF and FWS for review in lieu of the site assessment. If it is determined that suitable habitat is present, the appropriate survey will be recommended.

B. Site assessment - 20 m upstream / 80 m downstream. A site assessment is recommended to determine if suitable habitat is present at a project location and may be recommended if the presence of a Usted species is questionable. If suitable habitat is present, the appropriate survey will be recommended even in the absence of mussels, since the site assessment does not serve as a substitute for a mussel survey; however, the presence of freshwater mussels should be documented during the assessment.

C. Abbreviated survey - 100 m upstream / 400 m downstream of project footprint.

D. Full survey - 200 m upstream / 800 m downstream of project footprint.

The assessment/survey type is based on the scope of the project, potential impacts, and known species distributions. Survey lengths are measured from the project footprint. Survey distances have primarily been developed for projects where physical alteration/disturbance of the stream is the primary impact (e.g., bridge repair/replacement, utility line crossings, etc.). Potential impacts from projects involving activities such as point and non-point source discharges, water intakes, and mining may require greater survey lengths and different methods.

Project applicants should contract with a qualified mussel surveyor. Enclosures 3 and 4 provide a list of pre-approved mussel surveyors. If a pre-approved surveyor is not selected, please provide the proposed surveyor's qualifications and proposed survey design to FWS and VDGIF a minimum of 30 days prior to survey initiation. Individuals who take federally listed threatened © m

& m and endangered animals must obtain a permit from VDGIF, prior to surveying. Take is defined £§ as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to <80 engage in any such conduct. Contact information follows:

Ms: Shirl Dressier Virginia Department of Game and Inland Fisheries 4010 W. Broad Street P.O. Box 11104 Richmond, Virginia 23230-1104 Phone: (804)367-6913 [email protected]

A plan for mussel relocations, including initial surveys, must be presented to VDGIF and FWS (where applicable) for comment and approval prior to initiation of construction. FaUure to provide a mussel relocation and/or survey plan may affect review and permitting of the project by VDGIF and FWS.

The recommended time of year to conduct mussel surveys and relocations is April 1 through October 31. Surveying during the cooler months is discouraged because mussels tend to be located deeper in the substrate and a greater percentage of the population is subsurface, therefore making them more difficult to find, particularly rare species. A more specific time frame may be recommended depending on the target species. A survey conducted outside this time frame requires VDGIF and Service (where applicable) approval.

Guidelines if federally-listed mussels are not present

During the initial survey, mussel species within the direct project footprint or within imminent danger from project impacts may be relocated to suitable habitat unless otherwise directed by VDGIF. Suitable habitat typically includes an area upstream of project impacts and which also harbors freshwater mussels. If such an area cannot be found, the surveyor should determine the location of most suitable habitat. The direct project footprint shall be defined as the area of potentially disturbed substrate, any zone of heavy equipment operation, plus the distance downstream that may experience significant sedimentation from construction. If not determined prior to the relocation, the surveyor is responsible for determining the most suitable relocation area. All relocated mussels must be at least partially placed in the substrate, anterior end down. Project applicants may be required to monitor relocated mussels to determine relocation success/failure.

Standard mussel relocation protocols are outlined below. These protocols may vary based on factors such as the scope of the project and the results of the initial mussel survey. If the relocation protocols vary, VDGIF will clearly oudine the appropriate protocols with the project applicant. It is the project applicant's responsibility to ensure that the proper relocation protocols are used and that the contracted mussel surveyor is aware of any modifications to the standard protocols.

The reach from which mussels are to be relocated will be at least 100 m long including the project footprint. The standard protocol is as follows:

• The 1st relocation survey must occur within 30-45 days of instream construction activities and at least 7 days prior to the 2nd relocation survey.

• The 2nd relocation survey must occur within 30 days of instream construction activities and at least 7 days after the 1st relocation survey.

• All relocation surveys must include at a minimum, two passes. The target relocation percentage of the initial number of mussels collected is 80%. If on the 2nd pass, more than 20% of the initial number of mussels is collected, continued passes must be conducted until no more than 20% of the initial number of mussels is collected on the final pass. The target relocation percentage may be adjusted higher or lower depending on the species and numbers collected during the initial survey.

• If a state-listed species is found, continued passes must be conducted until no listed species are found on the final pass. If repeated passes result in continual collection of state-listed species, modification of the survey techniques may be required.

If relocation surveys are not possible due to natural conditions such as high water, contact VDGIF to arrange contingency plans.

The location of all relocated mussels must be accurately documented (preferably with geographic coordinates) and reported to VDGIF. All state-hsted mussel species must be tagged and measured for potential future monitoring.

Project applicants may be required to adhere to time of year restrictions for mussel relocations as directed by VDGIF. If this is the case, for the long-term brooders, relocations can occur from June 16 though August 14 and October 1 through October 31. For short-term brooders, relocations can occur from April 1 through May 14 and August 1 through October 31.

All mussel survey and relocation results, including tag and measurement data, must be submitted to VDGIF for review, prior to instream construction activities. Reviews will be expedited due to the potential short timeframe between surveys and/or relocations and the start of instream work. Reports must contain, at a minimum, number of species found, number of individuals per species and their sizes, and number of individuals tagged.

Guidelines if federally-listed mussel species are present

Federally-listed mussels must not be relocated during the initial survey. If federally-listed mussels are found, they must remain exactly where found and all specimens should be photo documented, if possible. Coordination with FWS and VDGIF must occur to determine future actions. P m m tn A a If it is determined that a project may affect a federally-listed species, FWS will complete a © consultation with the Federal action agency and prepare a biological opinion in accordance with the Federal Endangered Species Act. The relocation procedures for federally listed mussels will too be specified in FWS's biological opinion and will be determined on a project-specific basis.

If relocation surveys are not possible due to conditions such as high water, contact FWS and VDGIF to arrange contingency plans. All fisted mussels must be moved to suitable habitat upstream of any potential project impacts. Mussels may be relocated downstream if habitat upstream is determined unsuitable by VDGIF and FWS. If not determined prior to the relocation, the surveyor is responsible for determining the most suitable relocation area. All relocated mussels must be at least partially placed in the substrate, anterior end down. Project applicants may be required to monitor relocated mussels to determine relocation success/failure.

The location of all relocated federally-fisted mussels must be accurately documented (preferably with geographic coordinates) and reported to FWS and VDGIF. All federally-listed mussel species also must be tagged and measured for potential future monitoring.

All mussel survey and relocation results must be submitted to FWS and VDGIF for review, prior to instream construction activities. Reviews will be expedited due to the potential short timeframe between surveys and/or relocations and the start of instream work. Reports must contain, at a minimum; number of species found, number of individuals per species and their sizes, number of individuals tagged, etc.

Project applicants may be required to adhere to time of year restrictions (Enclosure 5) for mussel relocations as recommended by FWS' and VDGIF. Time of year restrictions will be specified in a letter or in FWS's biological opinion. p

©

a © Enclosure 3: Surveyor List for Atlantic Slope Mussels in Virginia W Approved Surveyors in Virginia for Atlantic Slope Freshwater Mussels fhttp://www.fws.gov/northeast/viTginiafield/pdl7endspecies/Survevor Lists/PDF%20Format/SU RVEYOR%20LIST%20-%20Atlantic%2QSlope%20Mussels.pdfl

Enclosure 4: Surveyor List for Upper Tennessee River Basin Mussels in Virginia

Approved Surveyors in Virginia for Tennessee River Drainage Freshwater Mussels ChttpV/www.fws.gov/northeast/virginiafield/pdf/endspecies/Survevor Lists/PDF%20Format/SU RVEY QR%2QLIST%20-%20TN%20Drainage%2QMussels.pdf 1

Enclosure 5: Time of Year Restrictions

Virginia Department of Game and Inland Fisheries Time of Year Restrictions (TOYR) Table (http ://www. dgif. Virginia, gov/ environmental-pro grams/files/VDGlF -Tim e-of-Y ear-Restrictions- Table.pdf)

Enclosure 6 - Federally-Designated Critical Habitat for Mussels in Virginia

Map of Federally-Designated Critical Habitat in Virginia ('http://fws.maps.arcgis.com/apps/Viewer/index.html?appid=f6e84e675bal461b8ae6a351adeal4 29) p

Molly Joseph Ward Rochelle.Altholz Secretary of Natural Resources Deputy Director of Administration and Finance Clyde E. Cristman Director David C. Dowling ^ Deputy Director of „ Soil and Water Conservation ® and Dam Safety

MEMORANDUM

DATE: April 14, 2016

TO: Julia Wellman, DEQ

FROM: Roberta Rhur, Environmental Impact Review Coordinator

SUBJECT: DEQ 16-049S, Cunningham-Dooms 500 kV Transmission Line Rebuild

Division of Planning and Recreation Resources

The Department of Conservation and Recreation (DCR], Division of Planning and Recreational Resources (PRR), develops the Virginia Outdoors Plan and coordinates a broad range of recreational and environmental programs throughout Virginia. These include the Virginia Scenic Rivers program; Trails, Greenways, and Blueways; Virginia State Park Master Planning and State Park Design and Construction.

The proposed project impacts several scenic resources. In Albemarle County, the project crosses the potentially scenic, Mechums River and Scenic Byway Route 20. We recommend crossing these two scenic resources in as perpendicular manner as possible and restore all land disturbance using native plant species. Further, the project route appears to cross federal lands and two nationally significant resources: the Appalachian Trail and the Blue Ridge Parkway. We recommend coordination with all federal partners and managing entities of these potentially impacted resources.

Division of Natural Heritage

The Department of Conservation and Recreation's Division of Natural Heritage (DCR) has searched its Biotics Data System for occurrences of natural heritage resources from the area outlined on the submitted map. Natural heritage resources are defined as the habitat of rare, threatened, or endangered plant and animal species, unique or exemplary natural communities, and significant geologic formations.

The following comments are provided by 1:24,000 quadrangles.

Waynesboro East Quad

This project is situated on karst-forming carbonate rock and can be characterized by sinkholes, caves, disappearing streams, and large springs. If such features are encountered during the project, please coordinate with Wil Orndorff (540-230-5960, [email protected] to document and minimize adverse impacts. Discharge of runoff to sinkholes or sinking streams, filling of sinkholes, and alteration of cave entrances can lead to surface collapse, flooding, erosion and sedimentation, groundwater contamination, and degradation of subterranean habitat for natural heritage resources. If the project

600 East Main Street, 24lh Floor | Richmond, Virginia 23219 | 804-786-6124

State Parks • Soil and Water Conservation • Outdoor Recreation Planning Natural Heritage • Dam Safety and Floodplain Management • Land Conservation p s* l/l involves filling or "improvement" of sinkholes or cave openings, DCR would-like detailed location ^ information and copies' of the design specifications. In cases where sinkhole improvement is for <© stormwater discharge, copies of VDOT Form EQ-120 will suffice. New "Karst Assessment ^ Guidelines" developed by the Virginia Cave Board for land development can be found at ^ httpi/Zwww.dgr,Virginia,gQv/natnral heritagg/documents/karst assesgmgnt gbidelmes.pdf.

Crozet Quad

According to the information currently in our files, the Mechums River - Stockton Creek Stream Conservation Unit is located within and downstream of the project site. Stream Conservation Units (SCUs) identify stream reaches that contain aquatic natural heritage resources, including 2 miles upstream and 1 mile downstream of documented occurrences, and all tributaries within this reach. SCUs are also given a biodiversity significance ranking based on the rarity, quality, and number of element occurrences they contain. The Mechums River - Miller Branch SCU has been given a biodiversity ranking of B2, which represents a site of very high significance. The natural heritage resources associated with this site are:

Pleurobema collina James spinymussel G1/S1/LE/LE Aquatic Natural Community (NP-Rivanna Second Order Stream] G3/S3/NL/NL

The James spinymussel is a freshwater mussel endemic to Virginia and is known from the James and Roanoke River watersheds. It occurs in a variety of substrata, ranging from sand and silt mixtures to gravel and sand mixed with rubble, and in a variety of flow regimes (Clarke & Neves, 1984; Hove & Neves, 1994]. It is now restricted to small headwater streams of this watershed (Neves, 1991].

Threats to the James spinymussel include competition with the exotic clam (Corbicula fluminea], erosion and sedimentation from logging, road construction, and livestock grazing, sewage effluent, and water quality degradation (Neves, 1991]. Please note that this species is currently classified as endangered by the United States Fish and Wildlife Service (USFWS] and the Virginia Department of Game and Inland Fisheries (VDGIF].

The documented Aquatic Natural Community is based on Virginia Commonwealth University's INSTAR [Interactive Stream Assessment Resource) database which includes over 2,000 aquatic (stream and river] collections statewide for fish and macroinvertebrate. These data represent fish and macroinvertebrate assemblages, instream habitat, and stream health assessments. The associated Aquatic Natural Community is significant on multiple levels. First, this stream is a grade B, per the VCU-Center for Environmental Sciences (CES], indicating its relative regional significance, considering its aquatic community composition and the present-day conditions of other streams in the region. This stream reach also holds a "Healthy" stream designation per the- INSTAR Virtual Stream Assessment (VSS] score. This score assesses the similarity of this stream to ideal stream conditions of biology and habitat for this region. Lastly, this stream contributes to high Biological Integrity at the watershed level (6th order) based on number of native/non- native, pollution-tolerant/intolerant and rare, threatened or endangered fish and macroinvertebrate species present.

In addition, Mechum River has been designated by the VDGIF as a "Threatened and Endangered Species Water." The species associated with this T & E Water is the James spinymussel.

Threats to the significant Aquatic Natural Community and the surrounding watershed include water quality degradation related to point and non-point pollution, water withdrawal and introduction of non-native species. To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations, establishment/enhancement of riparian buffers with native plant species and maintaining natural stream flow. p

un A Due to the legal status of the James spinymussel, DCR recommends coordination with the USFWS and ^ Virginia's regulatory authority for the management and protection of this species, the VDGIF, to ensure j® compliance with the Virginia Endangered Species Act (VA ST §§ 29.1-563 - 570). ^

Cdvesville Quad

According to the information currently in our files, the Rt. 708-North Fork Hardware River Stream Conservation Unit (SCU) is located within and downstream of the project site. The Rt. 708-North Fork Hardware River SCU has been given a biodiversity ranking of B5, which represents a site of general biodiversity significance. The natural heritage resource associated with this site is:

Stylurus laurae Laura's Clubtail G4/S2/NL/NL

Laura's clubtail {Stylurus laurae, G4/S2/NL/NL), a state rare dragonfly, ranges from Ohio south to Florida with westward records to Texas (Kondratieff, 2000). In Virginia, there are records across the Piedmont and west to the Ridge and Valley region. Its habitat consists of moderated gradient streams with many shallow riffles and runs (NatureServe, 2009).

Adult Odonata (dragonflies and damselflies), commonly seen flitting and hovering along the shores of most freshwater habitats, are accomplished predators. Adults typically forage in clearings with scattered trees and shrubs near the parent river. They feed on mosquitoes and other smaller flying insects, and are thus considered highly beneficial. Odonates lay their eggs on emergent vegetation or debris at the water's edge. Unlike the adults, the larvae are aquatic and typically inhabit the sand and gravel substrates/Wingless and possessing gills, the larvae crawl about the submerged leaf litter and debris stalking their insect prey. The larvae seize unsuspecting prey with a long, hinged "grasper" that folds neatly under their chin. When larval development is complete, the aquatic larvae crawl from the water to the bank, climb up the stalk of the shoreline vegetation, and the winged adult emerges (Hoffman 1991; Thorpe and Covich 1991).

Because of their aquatic lifestyle and limited mobility, the larvae are particularly vulnerable to shoreline disturbances that cause the loss of shoreline vegetation and siltation. Though somewhat tolerant .of decreased water quality, they are sensitive to alterations that result in poor water quality, aquatic substrate changes, and thermal fluctuations. Threats include activities that alter the water flow or substrate such as: impoundments, channelization, dredging, siltation, agricultural non-point pollution, and municipal and industrial pollution. In addition, timber harvest may increase siltation and cause a decrease in dissolved oxygen as canopy cover is.removed and water temperature rises (NatureServe, 2009).

To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations and that emergent vegetation adjacent to the creek be protected.

Alberene Quad

According to the information currently in our files, the Rt. 708-North Fork Hardware River Stream Conservation Unit (SCU) is located within and downstream of the project site. To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations and that emergent vegetation adjacent to the creek be protected, if instream work becomes necessary, DCR recommends surveys for rare freshwater mussels and coordination with VDGIF and USFWS to ensure compliance with protected species legislation. Simeon Quad

According to the information currently in our files, the Middle Fork - Cunningham Creek Stream Conservation Unit (SCU) is located within 2 miles of the project site. The Middle Fork - Cunningham Creek SCU has been given a biodiversity ranking of B2, which represents a site of very high significance. Natural heritage resource associated with this site is:

Aquatic Natural Community (NP-Rivanna Second Order Stream) G1G2/S1S2/NL/NL Aquatic Natural Community (NP-Rivanna Third Order Stream) G1G2/S1S2/NL/NL

The documented Aquatic Natural Community is based on Virginia Commonwealth University's INSTAR [Interactive Stream Assessment Resource) database which includes over 2,000 aquatic (stream and river) collections statewide for fish and macroinvertebrate. These data represent fish and macroinvertebrate assemblages, instream habitat, and stream health assessments. The associated Aquatic Natural Community is significant on multiple levels. First, this stream is a grade B, as per the VCU-Center for Environmental Sciences (CES), indicating its relative regional significance, considering its aquatic community composition and the present-day conditions of other streams in the region. This stream reach also holds a "Healthy" stream designation as per the INSTAR Virtual Stream Assessment (VSS) score. This score assesses the similarity of this stream to ideal stream conditions of biology and habitat for this region. Lastly, this stream contributes to high Biological Integrity at the watershed level (6th order) based on number of native/non- native, pollution-tolerant/intolerant and rare, threatened or endangered fish and macroinvertebrate species present.

Threats to the significant Aquatic Natural Community and the surrounding watershed include water quality degradation related to point and non-point pollution, water withdrawal and introduction of non-native species. To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations, establishment/enhancement of riparian buffers with native plant species and maintaining natural stream flow.

Boyd and Palmyra Quads

According to the information currently in our files, the Middle Fork - Cunningham Creek Stream Conservation Unit is located within and downstream of the project site. To minimize adverse impacts to the aquatic ecosystem as a result of the proposed activities, DCR recommends the implementation of and strict adherence to applicable state and local erosion and sediment control/storm water management laws and regulations. Please note that the Middle Fork - Cunningham Creek SCU is crossed four times by the proposed line rebuild and DCR emphasizes the importance of appropriate erosion and sediment control measures.

Under a Memorandum of Agreement established between the Virginia Department of Agriculture and Consumer Services (VDACS) and the DCR, DCR represents VDACS in comments regarding potential impacts on state-listed threatened and endangered plant and insect species. The current activity will not affect any documented state-listed plants or insects.

There are no State Natural Area Preserves under OCR's jurisdiction in the project vicinity. New and updated information is continually added to Biotics. Please re-submit a completed order form and project map for an update on this natural heritage information if the scope of the project changes and/or six months has passed before it is utilized.

The VDGIF maintains a database of wildlife locations, including threatened and endangered species, trout streams, and anadromous fish waters that may contain information not documented in this letter. Their o - m i/i database may be accessed from http://vafwis.org/fwis/ or contact Ernie Aschenbach at 804-367-2733 or .Jftt [email protected]. According to the information currently in our files, Hardware River, © which has been designated by the VDGIF as a "Threatened and Endangered Species Water" for the James © m spinymussel is within 2 miles of the project area in the Alberene quad. Therefore, DCR recommends © coordination with the USFWS and Virginia's regulatory authority for the management and protection of this species, the VDGIF, to ensure compliance with protected species legislation.

The remaining DCR divisions have no comments regarding the scope of this project. Thank you for the opportunity to comment.

CC: Troy Anderson, USFWS Ernie Aschenbach, VDGIF Wil Orndorff, DCR-Karst ta m © 1/1 a a Literature Cited ® iM <60 Clarke, A.H. and R.J. Neves. 1984. Status survey of the James River spinymussel, Canthyria collina, in the James River, Virginia. Unpublished report on file with the United States Fish and Wildlife Service, Newton Corner, Massachusetts.

Hoffman, R. 1991. Arthropods. Pp. 173 in: K. Terwilliger (ed.J, Virginia's Endangered Species: proceedings of a symposium. The McDonald and Woodward Publishing Company, Blacksburg, VA.

Hove, M.C. and R.J. Neves. 1994. Life history of the endangered James spinymussel Pleurobema collina (Conrad, 1837). American Malacological Bulletin 11:29-40.

Kondratieff, Boris C. (coordinator). 2000. Dragonflies and Damselflies (Odonata) of the United States. Jamestown, ND: Northern Prairie Wildlife Research Center Online. http://www.npwrc.usgs.gov/resource/distr/insects/dfly/index.htm (Version 12DEC2003). Accessed 25Mar2010.

NatureServe. 2009. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. (Accessed: March 25, 2010).

Neves, R.J. 1991. James spinymussel. In Virginia's Endangered Species: Proceedings of a Symposium. K. Terwilliger ed. The McDonald and Woodward Publishing Company, Blacksburg, Virginia.

Thorpe, J.H., and A.P. Covich. 1991. Ecology and Classification of North American Freshwater Invertebrates. Academic Press, Inc., San, Diego, California. Wellman, Julia (DEQ) © in From: nhreview (DCR) & Sent: Wednesday, May 04, 2016 2:11 PM m To: Wellman, Julia (DEQ) m Cc: Rhur, Robbie (DCR) <89 Subject: RE: DCR 09

Julia,

Both references should be for Mechums River-Stockton Creek Stream Conservation Unit. I apologize about the oversight.

Rene'

S. Rene' Hypes Project Review Coordinator Department of Conservation and Recreation Division of Natural Heritage 600 East Main Street, 24th Floor Richmond, Virginia 23219 804-371-2708 (phone) 804-371-2674 (fax) rene.hvpes(5)dcr.virginia.gov

Conserving VA's Biodiversity through Inventory, Protection and Stewardship http;//wvYW,cicr,Virginia,gov/natural-heritage/

From: Rhur, Robbie (DCR) Sent: Wednesday, May 04, 2016 1:55 PM To: nhreview (DCR) Subject: FW: DCR Importance: High

Can someone help Julia with this question

Thanks

From: Wellman, Julia (DEQ) Sent: Wednesday, May 04, 2016 1:02 PM l u To: Rhur, Robbie (DCR) gj, Subject: FW: DCR © Importance: High yri

Robbie, ® © «0 The first set of findings by DCR DNH state: According to the information currently in our files, the Mechums River - $0 Stockton Creek Stream Conservation Unit is located within and downstream of the project site. Stream Conservation Units (SCUs) identify stream reaches that contain aquatic natural heritage resources, including 2 miles upstream and 1 mile downstream of documented occurrences, and all tributaries within this reach. SCUs are also given a biodiversity significance ranking based on the rarity, quality, and number of element occurrences they contain. The Mechums River - Miller Branch SCU has been given a biodiversity ranking of B2, which represents a site of very high significance.

This paragraph first refer to the Mechums River-Stockton Creek SCU and then the Mechums River-Miller Branch SCU.

Which name is correct? Please clarify.

From: Rhur, Robbie (DCR) Sent: Thursday, April 14, 2016 11:46 AM To: Wellman, Julia (DEQ) Cc: Orndorff, Wil (DCR); Troy Andersen; dgif-ESS Projects (DGIF) Subject: DCR

Hi Julia:

Please see our comments

Robbie Rhur Environmental Review Coordinator/DCR 600 E Main Street 17th Floor Richmond VA 23219 804-371-2594

2 [=a Wellman, Julia (DEQ) § ——— _—^ From: Warren, Arlene (VDH) Sent: Wednesday, April 13,2016 2:30 PM •© To: Wellman, Julia (DEQ) & Co: Soto, Roy (VDH) 4# Subject: RE: NEW PROJECT SCO Cunningham-Dooms 500 kV Transmission Line Rebuild 16-049S

Project Name: Cunningham-Dooms 500 kV Transmission Line Rebuild Project #: 15-049S UPC#: N/A Location: Albemarle, Augusta, & Fluvanna Counties

VDH - Office of Drinking Water has reviewed the above project. Below are our comments as they relate to proximity to public drinking water sources (groundwater wells, springs and surface water intakes). Potential impacts to public water distribution systems or sanitary sewage collection systems must be verified by the local utility.

The following public groundwater wells are located within a 1 mile radius of the project site (wells within a 1,000 ft. radius are formatted in bold): PWSID District CNYCTY SYSNAME FACNAME 2003054 DISTRICT 10 ALBEMARLE ACSA RED HILL WELL #5 2003177 DISTRICT 10 ALBEMARLE CHARLOTTESVILLE KOA WELL 2003850 DISTRICT 10 ALBEMARLE CORVILLE FARM SUBDIVISION WELL C 2003665 DISTRICT 10 ALBEMARLE MISTY MOUNTAIN CAMP RESORT DEEP WELL 2003475 DISTRICT 10 ALBEMARLE MILLER SCHOOL WELL 2 2003475 DISTRICT 10 ALBEMARLE MILLER SCHOOL WELL 3 2003880 DISTRICT 10 ALBEMARLE .WALTON MIDDLE SCHOOL WL 2065783 DISTRICT 10 ALBEMARLE TENASKA WELL 2 2065783 DISTRICT 10 ALBEMARLE TENASKA WELL 1

The following surface water intakes are located within a 5 mile radius of the project site: PWSID SYSNAME FACNAME 2003600 OBSERVOIR WTP SUGAR HOLLOW RESERVOIR 2003250 CROZET WTP BEAVER CREEK RESERVOIR 2065480 LAKE MONTICELLO RIVANNA RIVER

The project is within the watershed of the following public surface water sources (intakes where the project falls within 5 miles into their watershed are formatted in bold): PWSID SYSNAME FACNAME 2003250 CROZET WTP BEAVER CREEK RESERVOIR 2003600 OBSERVOIR WTP SUGAR HOLLOW RESERVOIR 2065480 LAKE MOTICELLO RIVANNA RIVER 2003600 OBSERVATORY WTP RAGGED MOUNTAIN RESERVOIR 2003675 SCOTTSVILLE WTP TOTIER RESERVOIR INTAKE 2003675 SCOTTSVILLE WTP TOTIER CREEK INTAKE 4087125 HENRICO COUNTY WATER SYSTEM HENRICO RAW WATER INTAKE

1 2003725 SOUTH RIVANNA WTP SOUTH FORK RIVANNA RESERVOIR H 4075735 JAMES RIVER CORRECTIONAL JAMES RIVER INTAKE *"-• m 4761011 RICHMOND, CITY OF RAW WATER INTAKE £• 3670800 VIRGINIA-AMERICAN WATER CO. APPOMATTOX RIVER m a m Comments for Radiological Health, Mr. Steven Harrison: "does not have any questions or m comments"

Best Management Practices should be employed on the project site including Erosion & Sedimentation Controls as well as Spill Prevention Controls & Countermeasures.

The well(s) within the 1,000 ft. radius from project site, should be field marked and protected from accidental damage due to construction activities.

Care should be taken while transporting materials in and out of the project site, as to prevent impacts to surface water intakes within 5 miles.

There may be impacts to public drinking water sources due to this project if the mitigation efforts outlined above are not implemented.

Regards,

Arlene Fields Warren

Office of Drinking Water Virginia Department of Health 109 Governor Street Richmond, VA 23220 (804) 864-7781 88 COMMONWEALTH of VIRGINIA m DEPARTMENT OF ENVIRONMENTAL QUALITY Street address: 629 East Main Street, Richmond, Virginia 23219 Molly Joseph Ward Mailing address: P.O. Box 1105, Richmond, Virginia 23218 David K. Paylor Secretary of Natural Resources Fax: 804-698-4019 - TDD (804) 698-4021 Director www.deq.virginia.gov (804)698-4020 1-800-592-5482

Aprils, 2016

Dominion Virgima Power

Re: Cunningham-Dooms 500kV Transmission Line Rebuild

On March 17, 2016, the Department of Environmental Quality received the OEIR Review Request for the Cunningham-Dooms SOOkV Transmission Line Rebuild covering sites in Albemarle, Augusta and Fluvanna Counties, Virginia DEQ 's Division of Land Protection and Revitalization (DLPR) staff has reviewed your email and submittal and has the following comments concerning possible waste issues associated with this project:

Solid and hazardous waste issues were addressed in submittal. The request included a search of waste-related data bases.

Environmental Waste Database Searches:

When the environmental impact report is written or compiled, it should include an environmental investigation on and near the property to identify any hazardous waste sites or issues. The report author should analyze the data in the web-based Waste Division databases to determine if the project would affect or be affected by any sites identified in the databases. These are the CERCLA Facilities and Hazardous Waste Facilities databases.

CERCLA Facilities Database A list of active and archived CERCLA (EPA S.uperfund Program) sites.

Hazardous Waste Facilities Database A list of hazardous waste generators, hazardous waste transporters, and hazardous waste storage and disposal facilities. Data for the CERCLA Facilities and Hazardous Waste Facilities databases are periodically downloaded by the Waste Division from U.S. EPA's website.

Accessing the DEQ Databases: © Ufl The report author should access this information on the DEQ website at ^ http://www.deQ.virginia.gov/Programs/LandProtectionRevitalization/ReportsPublications/Origin ® alReports.aspx. Scroll down to the databases which are listed under Real Estate Search (uj Information heading. W

The Superfund information will be listed by clicking on the Search EPA's CERCLIS database tab and opening the file. Click on the locality box, click on sort, and then click on Datasheet View. Scroll to the locality of interest.

The hazardous waste information can be accessed by clicking on the Hazardous Waste Facility tab. Go to the Geography Search section and fill in the name of the city or county and VA in the state block, and hit enter. The hazardous waste facilities in the locality will be listed. The submittal identified 2 RCRA sites within 1.0 mile of the Rebuild Project The submittal indicates that neither of these sites falls within the right-of-way of the Rebuild Project

This database search will include most waste-related site information for each locality. In many cases, especially when the project is located in an urban area, the database output for that locality will be extensive.

DEQ's Virginia Geographical Information Systems (VEGIS) database can be accessed at the following web address: http://www.deq.virginia.gov/ConnectWithDEO/VEGIS.aspx. Through VEGIS's search options, you can identify by address (zip code) FUD sites, VRP sites, and Petroleum Release sites in the area of the proposed project. The submittal identified 53 petroleum sites within 1.0 mile of the Rebuild Project The submittal indicates that all of the petroleum release sites are located outside of the Rebuild Project right-of-way and are not expected to impact the Rebuild Project Please note that the DEQ's petroleum contamination (PC) case files may identify petroleum releases that should be evaluated by the project engineer or manager to establish the exact location of the release and the nature and extent of the petroleum release and the potential to impact the proposed project. The facihty representative should contact the DEQ's Valley Regional Office at 540-574-7800 (Tank Program) for further information and the administrative records of the PC cases which are determined to be in close proximity to the proposed project.

GENERAL COMMENTS:

Soil. Sediment and Waste Management

Any soil that is suspected of contamination or wastes that are generated must be tested and disposed of in accordance with applicable Federal, State, and local laws and regulations. Some of the applicable state laws and regulations are: Virginia Waste Management Act, Code of Virginia Section 10.1-1400 etseq.; Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC 20-60); Virginia Solid Waste Management Regulations (VSWMR) (9VAC 20-81); Virginia Regulations for the Transportation of Hazardous Materials (9VAC 20-110). Some of the applicable Federal laws and regulations are: the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. Section 6901 et seq., and the applicable regulations contained in Title 40 of the Code of Federal Regulations; and the U.S. Department of

2 p m a i/I Transportation Rules for Transportation of Hazardous Materials, 49 CFR Part 107. For more information contact DEQ's Valley Regional Office (Tanks Program) at 540-574-7800. ® © Asbestos and/or Lead-based Paint gg

Also, all structures being demolished/renovated/ removed should be checked for asbestos-containing materials (ACM) and lead-based paint (LBP) prior to demohtion. If ACM or LBP are found, in addition to the federal waste-related regulations mentioned above, State regulations 9VAC 20-80-640 for ACM and 9VAC 20-60-261 for LBP must be followed. Questions may be directed to Mr. Graham Simmerman in DEQ's VaUey Regional office, 540-574-7865.

Pollution Prevention - Reuse - Recycling

Please note that DEQ encourages all construction projects and facilities to implement pollution prevention principles, including the reduction, reuse, and recycling of all solid wastes generated. All generation of hazardous wastes should be minimized and handled appropriately.

If you have any questions or need further information, please contact Katy Dacey at (804) 698-4274.

3 Wellman, Julia (DEQ) <©

From: Narasimhan, Kotur (DEQ) & Sent: Monday, March 14, 2016 12:13 PM m To: Wellman, Julia (DEQ) a Subject: RE: Cunningham-Dooms 500 kV Rebuild m

Fluvanna, Albemarle, and Augusta counties are in attainment for both the 1-hour and 8-hour ozone standards.

Kotur

From: Wellman, Julia (DEQ) Sent: Monday, March 14, 2016 11:08 AM To: Narasimhan, Kotur (DEQ) Subject: Cunningham-Dooms 500 kV Rebuild

Hi Kotur,

The SCC has asked us to review the above-referenced transmission line rebuild project.

Are Fluvanna, Albemarle, and Augusta counties in attainment for both the 1-hour and 8-hour ozone standards?

Julia Wellman Environmental Impact Review Coordinator Department of Environmental Quality 629 E Main Street Richmond, VA 23219 (804) 698-4326 [email protected] www.deq.virqinia.qov

**** For program updates and public notices, please subscribe to the OEIR News Feed.****

i 0) DEPARTMENT OF ENVIRONMENTAL QUALITY § DIVISION OF AIR PROGRAM COORDINATION £>

ENVIRONMENTAL REVIEW COMMENTS APPLICABLE TO AIR QUALITY

TO: Julia H. Wellman DEQ - OEIA PROJECT NUMBER: DEQ #16-0498

PROJECT TYPE: X STATE EA / EIR • FEDERAL EA / EIS • SCC

• CONSISTENCY DETERMINATION

PROJECT TITLE: Cunningham-Dooms 500 kV Transmission Line Rebuild

PROJECT SPONSOR: State Corporation Commission

PROJECT LOCATION: X OZONE ATTAINMENT AREA

REGULATORY REQUIREMENTSMAY BE APPLICABLE TO: X CONSTRUCTION • OPERATION

STATE AIR POLLUTION CONTROL BOARD REGULATIONS THAT MAY APPLY: 1. • 9 VAC 5-40-5200 C & 9 VAC 5-40-5220 E - STAGE I 2. • 9 VAC 5-45-760 et seq. - Asphalt Paving operations 3. X 9 VAC 5-130 et seq. - Open Burning 4. X 9 VAC 5-50-60 et seq. Fugitive Dust Emissions 5. • 9 VAC 5-50-130 et seq. - Odorous Emissions; Applicable to_ 6. • 9 VAC 5-60-300 et seq. - Standards of Performance for Toxic Pollutants 7. • 9 VAC 5-50-400 Subpart , Standards of Performance for New Stationary Sources, designates standards of performance for the 8. • 9 VAC 5-80-1100 et seq. of the regulations - Permits for Stationary Sources 9. • 9 VAC 5-80-1605 et seq. Of the regulations - Major or Modified Sources located in PSD areas. This rule may be applicable to the. 10. Q 9 VAC 5-80-2000 et seq. of the regulations - New and modified sources located in non-attainment areas 11. • 9 VAC 5-80-800 et seq. Of the regulations - State Operating Permits. This rule may be applicable to

COMMENTS SPECIFIC TO THE PROJECT:

(Kotur S. Narasimhan) Office of Air Data Analysis DATE: March 24, 2016 Wellman, Julia (DEQ)

From: Gavan, Larry (DEQ) JSSi Sent: Wednesday, May 04,201611:31 AM <© To: Wellman, Julia (DEQ) © Subject: RE: NEW PROJECT SCC CUNNINGHAM DOOMS 16-049S

OK w/me. Thx L From: Wellman, Julia (DEQ) Sent: Wednesday, May 04, 2016 10:02 AM To: Gavan, Larry (DEQ) Subject: FW: NEW PROJECT SCC CUNNINGHAM DOOMS 16-049S

Larry,

Are the following the correct requirements to include for a Dominion rebuild project of an existing transmission line?

3(b)(i) Erosion and Sediment Control Annual Specifications, Stormwater Management and Local Program Compliance. In accordance with §62.1-44.15 et seq., electric, natural gas and telephone utility companies, interstate and intrastate natural gas pipeline companies, and railroad companies shall, and authorities created pursuant to § 5.2-5102 may, file general erosion and sediment control standards and specifications annually with DEQ for review and approval. Such standards and specifications shall be consistent with the requirements of this article and associated regulations and the Erosion and Sediment Control Law and Stormwater Management Act (§ 62.1-44.15:24 et seq.) and associated regulations where applicable. The specifications shall apply to:

• Construction, installation, or maintenance of electric transmission, natural gas, and telephone utility lines and pipelines, and water and sewer lines; and • Construction of the tracks, rights-of-way, bridges, communication facilities, and other related structures and facilities of the railroad company.

Construction of company buildings, facilities, and other structures are not covered by §62.1-44.15:55, and therefore, must comply with the requirements of the appropriate local erosion and sediment control program.

Dominion must have a certified Responsible Land Disturber in charge of and responsible for carrying out the project-specific erosion and sediment control plan and the land-disturbing activity. Dominion must contact [email protected] two weeks prior to land disturbance. Questions regarding annual erosion and sediment control specifications should be directed to DEQ.

3(b)(ii) Virginia Stormwater Management Plan General Permit for Construction Activities (VAR10). The operator or owner of construction activities involving land disturbance equal to or greater than one acre must register for coverage under the General Permit for Discharges of Stormwater from Construction Activities and develop a project-specific stormwater pollution prevention plan (SWPPP). Construction activities requiring registration also include the land disturbance of less than one acre of total land area that is part of a larger common plan of development or sale if the larger common plan of development will ultimately disturb equal to or greater than one acre. The SWPPP must be prepared prior to submission of the registration statement for coverage under the general permit, and the SWPPP must address water quality and quantity in accordance with the Virginia Stormwater Management Plan (VSMP) Permit Regulations. General information and registration forms for the general permit are available on DEQ's website at http://deq.virqinia.qov/Proqrams/Water/ StormwaterManagement.aspx. i COMMONWEALTH of VIRGINIA •DEPARTMENT OF ENVIRONMENTAL QUALITY Street address: 629 East Main Street, Richmond, Virginia 23219 Molly Joseph Ward Mailing address: P.O. Box 1105, Richmond, Virginia 23218 David K. Paylor Secretary of Natural Resources Fax: 804-698-4019 - TDD (804) 698-4021 Director www.deq.virginia.gov (804) 698-4000 1-800-592-5482

April 1,2016

Ms. Amanda Mayhew Dominion Virginia Power 701 East Gary Street, 12th Floor Richmond, Virginia 23129

RE: Wetland Impact Consultation; Proposed Cunningham-Dooms 500 kV Transmission Line Rebuild; Augusta, Albemarle and Fluvanna Counties, Virginia

Dear Ms. Mayhew:

In accordance with the Department of Environmental Quality-State Corporation Commission- Memorandum of Agreement Regarding Wetland Impact Consultation (July 2003), we have reviewed the information submitted by Dominion Virginia Power (here after, Dominion) regarding potential wetland impacts on the above referenced project. The purpose of the project is to rebuild approximately 32.7 miles of its existing 500 kV Cunningham-Dooms Line #534 transmission line in Augusta, Albemarle, and Fluvanna Counties located between its existing Cunningham Switching Station in Fluvanna County and its existing Dooms Substation in Augusta County.

Summary of Findings

According to an offsite wetland impact consultation report, prepared for Dominion by Stantec Consulting Services, Inc. (Stantec) and dated October 30,2015, both wetland areas and stream corridors were identified within the proposed transmission alignments. The approximate extent of these resources was derived from review of USGS topographic quadrangles, National Wetland Inventory (NWI) maps, pubhshed soil surveys for the localities within the proposed corridor, USGS digital stream and river data, USGS digital infrared orthophotography, and aerial photography.

The project area is entirely in existing Right of Way, and 23.76 miles of the overall 534 Rebuild project area have previously been delineated and confirmed. Areas of confirmed jurisdictional resources within the project area include 5.63 acres of wedands and 20,064 linear feet of stream.

Stantec performed a desktop review of the remaining project area and identified potential jurisdictional features as shown in the table below:

Page 1 of3 [pa 8t Cunningham-Dooms ® April 1,2016 ^ Stream PSS/PEM Channel m (Acres) m (Linear Feet) «8 6.33 3,410

Additionally, the wetland area probability of occurrence in the potential jurisdictional features is shown in the table below: High Medium Low Probability Probability Probability (Acres) (Acres) (Acres) < 0.30 2.76 3.27

DEQ recommends all wetlands and stream crossings within the proposed project alignment to be field debneated prior to detailed engineering, clearing activities, and construction. Structures should be sited to avoid wetlands to the extent practicable and should be sited outside of stream channels. Timbering debris should not be placed in wetlands or streams.

The DEQ Valley Regional Office (VRO) will make the final permitting decisions. Recommendations

Based upon review of all the information provided by Dominion we offer the following recommendations:

1. Prior to commencing project work, all wetlands and streams within the project corridor, should be field delineated and verified by the U.S. Army Corps of Engineers (the Corps), using accepted methods and procedures. 2. Wetland and stream impacts should be avoided and minimized to the maximum extent practicable. Stream impacts should be minimized or avoided by spanning the transmission line across each stream. No foundations should be placed within streambeds. Where access is required across a wetland, removable niats should be used to reduce compaction and rutting. Towers should be placed avoid wetlands, wherever possible. To the extent where any footings must be installed in wetlands, each footing should occupy the minimum space necessary. When excavation for a structure is necessary in a wetland, excess spoil should not be disposed of in adjacent wetland areas unless authorized by a state or federal wetland permit. 3. If the scope of the project changes, additional review will be necessary by this office. 4. At a minimum, compensation for impacts to State Waters, if necessary, should be in accordance with all applicable state wetland regulations and wetland permit requirements, including the compensation for permanent conversion of forested wetlands to emergent wetlands. 5. Any temporary impacts to surface waters associated with this project should require restoration to pre-existing conditions. 6. No activity may substantially disrupt the movement of aquatic fife indigenous to the water body, including those species, which normally migrate through the area, unless the primary purpose of the activity is to impound water. Culverts placed in streams must be installed to maintain low flow conditions. No activity may cause more than minimal adverse effect on navigation. Furthermore the activity must not impede the passage of normal or expected high flows and the structure or discharge must withstand expected high flows.

Page 2 of 3 Cunningham-Dooms April 1, 2016

7. Erosion and sedimentation controls should be designed in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992. These controls should be placed prior to clearing and grading and maintained in good working order to minimize impacts to state waters. These controls should remain in place until the area is stabilized and should then be removed. Any exposed slopes and streambanks should be stabilized immediately upon completion of work in each permitted area. All denuded areas should be properly stabilized in accordance with the Virginia Erosion and Sediment Control Handbook, Third Edition, 1992. 8. No machinery may enter surface waters, unless authorized by a Virginia Water Protection (VWP) permit. 9. Heavy equipment in temporarily impacted surface waters should be placed on mats, geotextile fabric, or other suitable material, to minimize soil disturbance to the maximum extent practicable. Equipment and materials should be removed immediately upon completion of work. 10. Activities should be conducted in accordance with any Time-of-Year restriction(s) as recommended by the Department of Game and Inland Fisheries, the Department of Conservation and Recreation, or the Virginia Marine Resources Commission. The permittee should retain a copy of the agency correspondence concerning the Time-of-Year restriction(s), or the lack thereof, for the duration of the construction phase of the project. 11. All construction, construction access, and demolition activities associated with this project should be accomplished in a manner that minimizes construction materials or waste materials from entering surface waters, unless authorized by a permit. Wet, excess, or waste concrete should be prohibited from entering surface waters. 12. Herbicides used in or around any surface water should be approved for aquatic use by the United States Environmental Protection Agency (EPA) or the U.S. Fish & Wildlife Service. These herbicides should be applied according to label directions by a licensed herbicide applicator. A non- petroleum based surfactant should be used in or around any surface waters. 13. Consider mitigating impacts to forested or converted wetlands by estabhshing new forested wetlands within the impacted watershed.

Finally, if the project quahfies for a Nationwide Permit 12 (NWP 12) from the Corps, then a Virginia Water Protection (VWP) permit is not necessary. If the applicant does not obtain a NWP 12, then a VWP permit may be necessary.

Should you have any questions, please don't hesitate to contact me at (804) 698-4074 or at [email protected].

Sincerely,

Hannah Schul VWP Permitting Specialist Office of Wetlands & Stream Protection

Cc: Keith Fowler, DEQ - VRO Bettina Sullivan, DEQ - Office of Environmental Review Michelle Henicheck, DEQ - Office of Wetlands & Stream Protection

Page 3 of 3 Wellman, Julia (DEQ) 1 1 Uri From: Schul, Hannah (DEQ) «£> Sent: Wednesday, May 04,2016 8:15 AM <© To: Wellman, Julia (DEQ) © Subject: RE: DEQ SCC Wetland Consult: Cunningham-Dooms 500 kV Transmission Line Rebuild

Hi Julia,

The recommendation applies to the areas that do not yet have confirmed field delineations.I apologize for not making that clearer in the letter.

Thanks!

Hannah Schul VWP Permitting Specialist

Office of Wetlands and Stream Protection Department of Environmental Quahty 629 E. Main Street Richmond, VA 23219

804-698-4074 [email protected]

From: Wellman, Julia (DEQ) Sent: Tuesday, May 03, 2016 3:54 PM To: Schul, Hannah (DEQ) Subject: FW: DEQ SCC Wetland Consult: Cunningham-Dooms 500 kV Transmission Line Rebuild Importance: High

Hi Hannah,

I noticed that your letter (as well as the SCC application) states that field delineations have been previously conducted and confirmed along 23.76 miles of the right-of-way.

Does the following recommendation apply to the entirety of the right-of-way (both areas with and without confirmed field delineations) or only to the areas for which confirmed field delineations have not occurred?

"Prior to commencing project work, all wetlands and streams within the project corridor should be field delineated and verified by the U.S. Army Corps of Engineers (the Corps), using accepted methods and procedures."

From: Sullivan, Bettina (DEQ) Sent: Friday, April 01, 2016 9:00 AM To: Wellman, Julia (DEQ) Subject: FW: DEQ SCC Wetland Consult: Cunningham-Dooms 500 kV Transmission Line Rebuild

Bettina Sullivan Manager Environmental Impact Review and Long Range Priorities Program Department of Environmental Quality 1 & Wellman, Julia (DEQ) <® Oi From: Fowler, Keith (DEQ) Sent: Friday, March 18, 2016 12:09 PM 0 To: Wellman, Julia (DEQ) a Subject: RE: NEW PROJECT SCC CUNNINGHAM DOOMS 16-049S m 0®

Below are DEQ Valley Regional Office review comments for the subject project. Other than the information provided below, I have no additional recommendations re this project. Please let me know if you need any additional information. 1. Water Quality and Wetlands. Measures must be taken to avoid and minimize impacts to surface waters and wetlands during construction activities. The disturbance of surface waters or wetlands may require prior approval by DEQ and/or the U.S. Army Corps of Engineers. The Army Corps of Engineers is the final authority for an official confirmation of whether there are federal jurisdictional wetlands or other surface waters that may be impacted by the proposed project. DEQ may confirm additional waters as jurisdictional beyond those under federal authority. Review of National Wetland Inventory maps or topographic maps for locating wetlands or streams may not be sufficient: there may need to be a site- specific review of the site by a qualified professional. Even if there will be no intentional placement of fill material in jurisdictional waters, potential water quality impacts resulting from construction site surface runoff must be minimized. This can be achieved by using Best Management Practices (BMPs). If construction activities will occur in or along any streams (perennial, intermittent, or ephemeral), open water or wetlands, the applicant should contact Eric Millard at DEQ- VRO (540-574-7813, [email protected]) to determine the need for any permits prior to commencing work that could impact surface waters or wetlands.

2. Erosion and Sediment Control and Storm Water Management. DEQ has regulatory authority for the Virginia Pollutant Discharge Elimination System (VPDES) programs related to municipal separate storm sewer systems (MS4s) and construction activities. Erosion and sediment control measures are addressed in local ordinances and State regulations. Additional information is available at http://www.deQ.virainia.aov/ProaramsA/Vater/StormwaterManaaement.asox. Non-point source pollution resulting from this project should be minimized by using effective erosion and sediment control practices and structures. Consideration should also be given to using permeable paving for parking areas and walkways where appropriate, and denuded areas should be promptly revegetated following construction work. If the total land disturbance exceeds 10,000 square feet, an erosion and sediment control plan will be required. Some localities also require an E&S plan for disturbances less than 10,000 square feet. A stormwater management plan may also be required. For any land disturbing activities equal to one acre or more, you are required to apply for coverage under the VPDES General Permit for Discharges of Storm Water from Construction Activities. The Virginia Stormwater Management Permit Authority may be DEQ or the locality. Specific questions regarding the Stormwater Management Program requirements should be directed to Gary Flory at DEQ-VRO (540-574-7840, [email protected]).

3. Other Site Development Considerations. Fugitive dust generated during construction should be controlled by using measures such as the prompt removal of spilled or tracked dirt or other materials from paved streets, limited application of water to suppress dust, and washing of construction vehicles and paved roadways immediately adjacent to construction sites. Do not use water for dust control to the extent that it results in runoff to surface waters or wetlands: Land clearing wastes (vegetative debris) generated during construction should be properly managed in accordance with applicable regulations and local ordinances. Shredding/chipping of vegetative debris and reuse on-site is usually recommended over open burning. Any open burning of vegetative debris must be performed in accordance with the Open Burning Regulation and coordinated with the local fire official to ensure that all local ordinances are met. A copy of DEQ's open burning regulation and related information are accessible from http://www.dea.virainia.aov/Proarams/Air/AirQualitvPlans/OpenBurnina.aspx. Also, no open burning should take place in violation of the Virginia Waste Management Regulations, http://law.lis.virainia.Qov/admincode/title9/aQencv20/. Contact Keith Fowler at DEQ-VRO (540-574-7812, [email protected]) for any questions related to the proper control of fugitive dust, or open burning requirements and prohibitions. 4. Air Quality. Installation / operation / modification of stationary or portable fuel burning equipment (e.g., generators, wood chippers/grinders, etc.) or other sources of air pollutants may be subject to registration and/or air permitting requirements (http://www.dea.virainia.Qov/Proarams/Air/PermittinaCompliance/PermittinQ/TvpesofAirPermits.aspx): for questions regarding this, please contact Janardan Pandey at DEQ-VRO (540-574-7817, [email protected]).

l p 5. Petroleum Storage Tanks. Installation / operation / modification of tanks used for the storage of petroleum and CERCLA substances may be subject to registration and/or other regulatory requirements (http://www.dea.virqinia.qov/Proqrams/LandProtectionRevitalization/PetroleumProqram/StoraaeTanks.asDxt. If LH petroleum-contaminated soils or water are encountered during excavation work, or if old petroleum tanks need to be ^ removed or replaced, contact DEQ. For questions regarding any of this, please contact David Forrer at DEQ-VRO (540- <9 574-7837. [email protected]. @ m 6. Solid and Hazardous Wastes, and Hazardous Substances. DEQ administers the Virginia Waste Management Regulations, http://law.lis.virainia.aov/admincode/title9/aqencv20/. All solid wastes, hazardous wastes, and hazardous materials, including construction and demolition (C&D) wastes and universal wastes (batteries, fluorescent lights, refrigerants, mercury switches, mercury thermostats, etc.), must be managed in accordance with all applicable federal, state, and local environmental regulations. The generation of hazardous wastes should be minimized and solid wastes generated at the site should be reduced at the source, reused, or recycled. DEQ encourages the management of certain organic wastes by on-site composting or reuse as animal feed or soil amendment. Also, if you encounter any improperly disposed solid or hazardous wastes, or petroleum contaminated soils, you should contact DEQ-VRO. You may wish to refer to the web link for "What's in My Back Yard?", http://www.dea.virainia.aov/ConnectWithDEQ/VEGIS.aspx. to help you determine areas where residual contamination may be more likely. Contact Graham Simmerman at DEQ-VRO (540- 574-7865, [email protected] for any questions related to waste management / disposal. Manage / dispose of any asbestos-containing materials (ACMs) in accordance with Virginia Department of Labor and Industry (DOLI) regulations. Contact Doug Wiggins at DOLI ([email protected]. 540-562-3580, ext. 131) for any questions related to management / disposal of ACMs. Any open burning must be conducted in compliance with the Open Burning Regulation, httP.7/law.lis.virainia.aov/admincode/title9/aaencv5/chapter1301. Contact Keith Fowler at DEQ-VRO (540-574-7812, [email protected] for any questions related to open burning requirements and prohibitions.

7. Pesticides and Herbicides. DEQ recommends that herbicides or pesticides for construction or landscape maintenance, when necessary, be used in accordance with the principles of integrated pest management, and that the least toxic pesticides that are effective in controlling the target-species be used. Please contact the Department of Agriculture and Consumer Services at (804) 786-3501 for more information. If applying aquatic pesticides to surface waters, the applicant must comply with the DEQ's Pesticide General Permit, http://www.dea.virainia.aov/Proarams/Water/Perm ittinaCompliance/PoilutionDischarqeElimination/PermitsFees.aspx#pest

8. Natural Heritage Resources. The Virginia Department of Conservation and Recreation (DCR) Division of Natural Heritage (DNH) can search its Biotics Data System for occurrences of natural heritage resources from the area indicated on the submitted map. Natural heritage resources are defined as the habitat of rare, threatened, or endangered animal and plant species, unique or exemplary natural communities, and significant geologic communities. We recommend that the DNH be contacted at (804) 786-7951 to secure updated information on natural heritage resources before commencing the project. 9. Wildlife Resources. The Virginia Department of Game and Inland Fisheries (DGIF) exercises enforcement and regulatory jurisdiction over wildlife and freshwater fish, including state or federally listed endangered or threatened species. DGIF determines likely impacts on fish and wildlife resources and habitat, and recommends appropriate measures to avoid, reduce, or compensate for those impacts. For more information, see the DGIF website at httD://www.daif.virainia.aov or contact Ray Fernald at (804) 367-6913.

10. Historic and Archaeological Resources. Section 106 of the National Historic and Preservation Act of 1966, as amended, requires that activities that receive federal funding must consider effects to properties that are listed or eligible for listing on the National Register of Historic Places. The Department of Historic Resources (DHR) conducts reviews of projects to determine their effect on historic structures or cultural resources. If applicable, contact DHR. In the event that archaeological resources are encountered during construction, immediately contact Ms. Ethel Eaton, DHR, at (804) 367- 2323. 11. Pollution Prevention. DEQ recommends that construction projects incorporate the principles of pollution prevention including the following recommendations: • Consider environmental attributes when purchasing materials. For example, the extent of recycled material content and toxicity level should be considered. • Consider contractors' commitment to the environment when choosing contractors. Also, specifications regarding raw material selection (alternative fuels and energy sources) and construction practices can be included in contract documents and requests for proposals. • Choose sustainable practices and materials in infrastructure and construction and design. These could include asphalt and concrete containing recycled materials and integrated pest management in landscaping. 2 P • Integrate pollution prevention techniques into maintenance and operation activities to include source reduction m (fixing leaks, energy efficient products). •Si Pollution prevention measures are likely to reduce potential environmental impacts and reduce costs for material ijn purchasing and waste disposal. DEQ's Office of Pollution of Prevention hosts a number of programs and initiatives that provide non-regulatory assistance to businesses, institutions, and communities including the Virginia Environmental Excellence Program and Virginia Green. For more information, please visit our web site at © http://www.dea.virainia.aov/Proqrams/PollutionPrevention.asDx. m

12. Energy Conservation. Any structures should be planned and designed to comply with state and federal guidelines and industry standards for energy conservation and efficiency. For example, energy efficiency of the structures can be enhanced by maximizing the use of the following: • thermallyTefficient building shell components (roof, wall, floor, and insulation); • high efficiency heating, ventilation, air conditioning systems; and • high efficiency lighting systems. Matt Heller at the Department of Mines, Minerals and Energy, (434) 951-6351, may be contacted for assistance in meeting this challenge. 13. Potable Water. Installation of potable water lines and appurtenances must comply with the State's Waterworks Regulations. The Virginia Department of Health (VDH), http://www.vdh.state.va.us/ODW/. administers both federal and state laws governing waterworks operation. For more information, contact the VDH's Lexington Office of Water Programs at (540) 463-7136.

14. Wastewaters. DEO has approval authority over wastewater discharges per the State Water Control Law and corresponding regulations. This includes discharges or land application of any wastewaters generated from washing of materials, products, or vehicles, or other practices relevant to this project. DEQ also has approval authority over plans and specifications for sewage collection systems and treatment works (except drainfields and other on-site systems approved by the local health department), per the Sewage Collection and Treatment (SCAT) Regulations, http://law.lis.virqinia.aov/admincode/title9/aaencv25/chapter790/. Any wastewaters generated by this project must be properly managed and disposed. For additional information and assistance, contact Brandon Kiracofe at.DEQ-VRO (540- 574-7892, [email protected]).

B. Keith Fowler | Deputy Regional Director | DEQ-Valley Regional Office | 4411 Early Road | P. O. Box 3000 | Harrisonburg, VA 22801 | 540-574-7812 | Keith,Fow|er@deq,virqinig.qov

From: Fulcher, Valerie (DEQ) Sent: Thursday, March 17, 2016 3:38 PM To: dgif-ESS Projects (DGIF); Tignor, Keith (VDACS); Rhur, Robbie (DCR); odwreview (VDH); Coe, Stephen (DEQ); Narasimhan, Kotur (DEQ); Henicheck, Michelle (DEQ); Gavan, Larry (DEQ); Sepety, Holly (DEQ); Fowler, Keith (DEQ); Kirchen, Roger (DHR); Spears, David (DMME); Evans, Gregory (DOF); Watkinson, Tony (MRC); Ray, Alfred C. (VDOT); Cromwell, James R. (VDOT); Jordan, Elizabeth (VDOT); Riedesel, Bonnie S.; [email protected]; Foley, Thomas; Coffield, Pat; [email protected]; Harrington, Rusty N. (DOAV); ImpactReview (VOF) Cc: Wellman, Julia (DEQ) Subject: NEW PROJECT SCC CUNNINGHAM DOOMS 16-049S

Good afternoon - this is a new OEIR review request/project:

Document Type: SCC Application Project Sponsor: State Corporation Commission Project Title: Cunningham-Dooms 500 kV Transmission Line Rebuild Location: Albemarle, Augusta, & Fluvanna Counties Project Number: DEQ #16-0495

The document is available at www.deo.vireinia.gov/fileshare/oeir in the STATE CORPORATION COMMISSION folder.

3 COMMONWEALTH of VIRGINIA

Moiiy Joseph ward Department of Historic Resources Jnu.lie v Unean Secretary of Natural Resources . , ' . , Director 2801 Kensington Avenue, Richmond, Virginia 23221 Tel: (804) 367-2323 Fax: (804) 367-2391 www.dhr.virginia.gov

April 14, 2016

Ms. Julia Wellman DEQ - OEIR 629 E. Main Street, Sixth Floor Richmond, VA 23219

Re: Cunningham to Dooms SOOkV Transmission Line Rebuild, PUE 2016-00020 Augusta, Albemarle, and Fluvanna Counties, Virginia DHR File No. 2015-1105; DEQ#16-049S

Dear Ms. Wellman:

We have received for review the State Corporation Commission (SCC) application prepared by the Virginia Electric and Power Company (Dominion) for the project referenced above. The below comments are provided as technical assistance to DEQ and the SCC in the review of this application. We have not been notified by any Federal agency of their involvement in this project; however, we reserve the right to provide additional comment pursuant to the National Historic Preservation Act, if applicable.

Dominion's pre-application analysis, included in the SCC apphcation as DEQ Supplement, Attachment 2.H.2, considers the potential impact of the proposed project on recorded archaeological sites and on known historic architectural properties listed or previously determined eligible for listing in the Virginia Landmarks Register (VLR) and the National Register of Historic Places (NRHP) within a tiered study area. DHR's comments on the pre-application analyses are provided in the attached tables and utilize the following scale in describing impacts:

• None - Project is not visible from the property • Minimal - Occur within viewsheds that have existing transmission lines, locations where there will only be a minor change in tower height, and/or views that have been partially obstructed by intervening topography and vegetation. • Moderate - Include viewsheds with expansive views of the transmission line, more dramatic changes in the line and tower height, and/or an overall increase in the visibility of the route from the historic properties. • Severe - Occur within viewsheds that do not have existing transmission lines and where the views are primarily unobstructed, locations where there will be a dramatic increase in tower visibility due to the close proximity of the route to historic properties, and viewsheds where the visual introduction of the transmission line is a significant change in the setting of the historic properties.

Administrative Services Eastern Region Office Western Region Office Northern Region Office 10 Courthouse Ave. 2801 Kensington Avenue 962 Kime Lane 5357 Main Street Petersburg, VA 23803 Richmond, VA 23221 Salem, VA 24153 PO Box 519 Tel: (804) 862-6408 Tel: (804) 367-2323 Tel: (540) 387-5443 Stephens City, VA 22655 Fax: (804) 862-6196 Fax:(804)367-2391 Fax: (540) 387-5446 Tel: (540) 868-7029 Fax: (540) 868-7033 >a ft Page 2 ® April 14,2016 DHR File No. 2015-1105 &

To summarize, the pre-application analysis identified nine (9) VLR/NRHP-listed landmarks and historic districts, including one (1) National Historic Landmark, and one (1) VLR/NRHP-eligible historic district within the tiered study area.

Based upon a review of the information provided, we concur that four (4) architectural resources will have no impacts, four (4) resources will have minimal impacts, and one (1) resource will have moderate impacts from the proposed 500kV rebuild. We do not concur that there will be minimal impacts to the Greenwood-Afron Rural Historic District, and recommend that the impacts will be moderate. See the attached table for details regarding these recommendations.

Ten previously identified archaeological sites are located within or immediately adjacent to the right-of- way. One (1) has been determined potentially eligible for VLR/NRHP listing and the remaining have not been evaluated. VLR/NRHP eligibility of these sites and potential impacts of the project should be considered as part of the additional studies recommended below.

Impacts to unrecorded or unevaluated historic resources have not yet been considered. Consistent with DHR's Guidelines and the consultant's findings, we recommend the following:

1. Comprehensive archaeological and architectural surveys in accordance with DHR guidelines by qualified professionals prior to construction of any SCC-approved alternative. Areas previously subjected to archaeological survey do not need to be resurveyed, but identified sites must be evaluated. 2. Evaluation of all identified resources for listing in the VLR/NRHP. 3. Assessment of potential direct and indirect impacts to all VLR/NRHP-eligible resources, including previously inaccessible properties. 4. Avoidance, minimization, and/or mitigation of moderate to severe impacts to VLR/NRHP- eligible resources by Dominion in consultation with DHR and other stakeholders.

Thank you for the opportunity to review this apphcation. If you have any questions concerning these comments, please contact me at [email protected].

Sincerely,

Roger W. Kirchen, Director Review and Compliance Division

Administrative Services Eastern Region Office Western Region Office Northern Region Office 10 Courthouse Ave. 2801 Kensington Avenue 962 Kime Lane 5357 Main Street Petersburg, VA 23803 Richmond, VA 23221 Salem, VA 24153 PO Box 519 Tel: (804) 862-6408 Tel: (804) 367-2323 Tel: (540) 387-5443 Stephens City, VA 22655 Fax: (804) 862-6196 Fax: (804) 367-2391 Fax: (540) 387-5446 Tel: (540) 868-7029 Fax:(540)868-7033 Attachment - Pre-Application Analysis Historic Resources April 14, 2016 DHR File No; 2015-1105

002-0067 Redlands VLR/NRHP 4,000 ft. None None Listed 002-0071 Seven Oaks Farm VLR/NRHP 2,300 ft. None None Listed 002-0086 The Cedars VLR/NRHP 1,800 ft. None None Listed 002-0100 Mirador VLR/NRHP 4,800 ft. None None Listed 002-0174 Miller School of VLR/NRHP 700 ft. Minimal Minimal Albemarle Listed 002-0734 Anchorage Farm VLR/NRHP 2,800 ft. Minimal Minimal Listed 002-5045 Jefferson Carter. VLR/NRHP Within. ROW Moderate. Moderate Rural Historic- Listed. District. 002-5075 Greenwood- Afton VLR/NRHP Within ROW Minimal Moderate Rural Historic, ' Listed District- 069-0234 Skyline Drive VLR/NRHP Within ROW Minimal Minimal Historic District and Listed; NHL Extension 093-5043 Appalachian Trail, VLR/NRHP Within ROW Minimal Minimal Shenandoah Eligible National Park 44AB0096 Prehistoric - Not evaluated Within ROW None TBD unknown 44AB0573 Prehistoric Lithic Not evaluated Within ROW None TBD Scatter 44AB0574 Prehistoric Lithic Not evaluated Within ROW None TBD Scatter 44AB0575 Historic Trash Not evaluated Within ROW None TBD Scatter-20,hc. 44AB0576 Historic Trash Not evaluated Within ROW None TBD Scatter-19'h to 20th c. domestic 44AB0577 Historic Trash Not evaluated Within ROW None TBD Scatter-ig1" to 20,h c. domestic 44AU0830 Prehistoric Lithic Not evaluated Within ROW None TBD Scatter-19^ to 20lh c. domestic 44AU0831 Prehistoric Lithic Not evaluated Within ROW None TBD Scatter 44AU0832 Prehistoric Lithic Not evaluated Within ROW None TBD Scatter 44AU0833 Prehistoric Lithic Potentially Within ROW None TBD Reduction Site Eligible (DHR 2012) & (ft m i/I

a a m m COMMONWEALTH of VIRQINIA

DEPARTMENT OF TRANSPORTATION 1601 Orange RoatJ Culpeper^ Virginia-22701 Charles A. Kilpatrick, P.E. Commissioner

April 14,2016

Julia Wellman Virginia Department of Environmental Quality 629 East Main Street, 6(h Floor Richmond, VA 23219

RE: Dominion Virginia Power's Cunningham-Dooms 500 kV Transmission Line Rebuild located in Augusta,. Albemarle, and Fluvanna Counties

Dear Ms. Wellman,

The Virginia Department of Transportation (VDOT) Staunton District and Culpeper District Planning has completed the review of the materials dated March 2, 2016 .This project will consist of the replacement of transmission towers, lines, and other components of Line #534 along a 32.7 mile total segment between the existing Dooms Substation in Augusta County through Albemarle County and on to the existing Cunningham Switching Station in Fluvanna County. All work associated with the project will occur within the existing-transmission line right-of-way with.the, exception of VDOT road crossings over secondary, primary and Interstate 64. Any required work that will encroach into the right-or-way or easements of state maintained roadways or impacts vehicular traffic operations will be required to comply with VDOT's Land Use Permit Regulations (24 VAC 30-151) and work areas will comply with the 2011 Virginia Work Area Protection Manual's Latest Edition. Based on the alignment of the existing right-of- way of Line #534, the project will consist of an approximately 4.2 mile segment in Augusta County that will cross the following state-maintained public roadways: Route 611, Dooms Crossing Road and Route 622, Calf Mountain Road. In Albemarle County there will be numerous state secondary road crossings along with primary routes to include Routes 20, 29 and Route 250. There will be some secondary roads also impacted with road crossings in Fluvanna County as well.

Additionally, from a non-transportation standpoint VDOT recommends consideration and discussions with all appropriate agencies and localities regarding the rebuild project of Line #534, especially given the alignment of this project crossing Shenandoah National Park and the Appalachian Trail Corridor.

Additional concerns to be reviewed and approved will be:

Construction Entrance Locations for sight distance and entrance design. Advance Construction Entrance signage to be placed prior to entrance on both sides. Work Zone Plans and Permits for all crossings to be submitted and reviewed prior to work starting. Allow 30 days for review and approval of crossings for Routes 1-64 and 250. Permits to be issued for each location separately and can be inspected and released as each of the sections are completed. Additional details will be available when reviews of the construction entrances have started. Please contact me if you have questions or concerns about VDOT requirements concerning this project, I can be reached at (434) 531-2877.1 look forward to working with you on this project.

Sincerely,

Dennis Scale Engineering Specialist Culpeper District Charlottesville Residency

CC: Elizabeth Jordan, Ph. D., VDOT Jim Cromwell, VDOT Chip Ray, VDOT Terry Short Jr., VDOT

WE KEEP VIRGINIA MOVING

WE KEEP VIRGINIA MOVING Hi Si o \n A VIRGINIA OUTDOORS a FOUNDATION © March 30,2016 «s m

VIA Email

Ms. Julia Welman Department of Environmental Quality (DEQ) Office of Environmental Impact Review • 629 E. Main St., 6th Floor Richmond, VA 23219

RE: PUE 2016-00020; DEQ #16-0498 Dominion Virginia Power's Proposed Transmission Project Dooms - Cunningham 500kV Line Rebuild Augusta, Albemarle and Fluvanna Counties

Dear Ms. Welman:

The Virginia Outdoors Foundation (VOF) is in receipt of an email from Ms. Valerie Fulcher of DEQ, dated March 17, 2016, concerning the above-referenced project. We thank you for the opportunity to provide additional comments regarding upgrades to the electric transmission corridor funning through VOF open-space easements in the aforementioned counties. This project is located in a region of Virginia that contains a high concentration of our open-space easements.

VOF, an agency of the Commonwealth, was established by the General Assembly in 1966 to promote the preservation of Virginia's natural and cultural resources by encouraging private philanthropy in fulfillment of state policy. As a result of Virginia's commitment to ensure a vibrant natural environment for today and future generations, VOF owns thousands of acres managed for public access and holds more than 3,600 easements across the Commonwealth, and these easements protect in perpetuity over 780,000 acres of open-space.

This transmission line was constructed in the mid-1960s with "COR-TEN" weathering steel towers and according to Dominion, has now reached the end of its 50-year expected life span. Dominion is proposing to replace the towers with galvanized steel lattice towers that will be approximately 20-30' taller than the existing towers. The proposed galvanized towers could have a significant visual impact along the corridor in this highly scenic area of Central Virginia.

Dominion states that the proposed rebuild will occur within the existing ROW. While the replacement may occur within the existing ROW, VOF requests additional information on whether there are existing forests or vegetation that will need to be cleared, including any clearing outside of the official ROW in the "safety fall zone." VOF also requests additional information on whether any of the temporary construction infrastructure (roads, bridges, etc.) will need to occur on open-space easement property.

virginiaoutdoorsfoundation.org

Richmond Office | 600 E. Main Street, Suite 402, Richmond, VA 23219-2416 Page 1 of 3 I p

e U1 & a VOF holds open-space easements on 25 properties within 1.5 miles of the transmission line, a <• majority of which could be visually-impacted by the proposed rebuild and upgrade to galvanized steel lattice towers. Of those 25 properties, the line physically crosses 4 properties Under open- ^ space easements within Dominion's existing ROW. Dominion has stated that since the proposed project is the rebuild of an existing transmission line and no additional right-of-way is required, no impact to conservation easements is expected. .However, should the proposal require any additional ROW through a VOF easement, Dominion will need complete a utility easement apphcation. Staff will evaluate the request according to the specific conservation values of each easement in deterxnining the feasibility of additional utility right of way, which determination will be transmitted to the board for final approval. Please contact VOF staff to request this application and please note that Dominion is required to obtain separate approval from the fee owner of the subject property.

In considering the impact of this proposal on conservation lands, an open-space easement is a legal interest in real property that creates a relationship between the holders of the easement and the property owner. By means of the easement, VOF has an interest in specific conservation values of the property and a legal obligation to protect these values. VOF easements provide important public benefits by protecting in perpetuity significant tracts of mostly undeveloped land which may contribute to the protection of water quality, productive soils, natural heritage resources, historic resources, and scenic viewsheds. VOF easements represent over $1 billion of public investment and fulfillment of Title XI of the Virginia Constitution and other public policies to ensure conservation of natural and cultural resources. These investments in conservation and future conservation opportunities may be jeopardized if large-scale utility development impairs the protected resources and their character-defining setting. Degradation of protected resources may result in a loss of confidence in the effectiveness of conservation easements by the public.

As mentioned above, the proposed project both crosses protected lands, and will be in the viewshed of many others. VOF is concerned about the potential impact that a large-scale utility development like this may have on the scenic viewsheds and pastoral settings provided by these protected properties, especially for the driving public along Interstate 64, US Route 29, US Route 250 and State Route 20. As such, VOF requests that full consideration be given to the importance of these open-space properties and their extensive conservation values in the upgrading of this transmission corridor.

Specifically, VOF is concerned about the proposed galvanized steel lattice towers. Alternatives of less visual impact should be fully considered and modifications to siting, location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values. If the SCO certificate is issued, the permit should require implementation of all industry best practices, including, but not limited to (1) minimal removal of vegetation through use of a clearing plan and (2) use of non- reflecting or de-glared conductors and dulled steel for towers and structures.

virginiaoutdoorsfoundation.org'

Richmond Office | 600 E. Main Street, Suite 402, Richmond, VA 23219-2416

Page 2 of 3 p <30 © Wi £ © Thank you for the notice and we look forward to working with you and Dominion in the ® continued planning and evolution of this project. If you have any further questions or comments, please feel free to contact me at (804) 577-3337 or [email protected].

Sincerely,

Martha Little Deputy Director, VOF

cc: Amanda Mayhew, Dominion (via email) Brian Fuller, VOF (via email) ' Tracy Hibbitts, VOF (via email) Mike Hallock-Solomon, VOF (via email)

virginiaoutdoorsfoundation.org

Richmond Office | 600 E. Main Street, Suite 402, Richmond, VA 23219-2416

Page 3 of3 Wellman, Julia (DEQ)

From: Charlotte P McAfee (Services - 6) ^ Sent: Monday, April 18,2016 3:06 PM a To: Wellman, Julia (DEQ) © Subject: RE: Cunningham-Dooms 500 kV Transmission Line, PUE-2016-00020 / DEQ #16-0498 m

Sorry for my delay - Dominion does not intend to provide a further response. Thank you for checking.

From: Wellman, Julia (DEQ) [mailto:[email protected]] Sent: Friday, April 15, 2016 3:58 PM To: Charlotte P McAfee (Services - 6) Subject: FW: Cunningham-Dooms 500 kV Transmission Line, PUE-2016-00020 / DEQ #16-0495

Does Dominion plan on responding or reaching out to VOF to discuss?

From: Little, Martha (VOF) Sent: Friday; April 15, 2016 3:18 PM To: Charlotte P McAfee (Services - 6); Wellman, Julia (DEQ) Cc: Amanda M Mayhew (VirginiaPower - 6); G. W. Jackson (VirginiaPower - 6) Subject: RE: Cunningham-Dooms 500 kV Transmission Line, PUE-2016-00020 / DEQ #16-0495

Julia and Charlotte, VOF would like to respond with the following:

We appreciate Dominion Virginia Power's responses to the concerns outlined in our letter dated, March, 29 2016 regarding: PUE 2016-00020; DEQ #16-049SDommion Virginia Power's Proposed Transmission Project Dooms - Cunningham 500kV Line Rebuild Augusta, Albemarle and Fluvanna Counties

VOF would like to reiterate the points made in that letter and specifically the following points: "VOF is concerned about the proposed galvanized steel lattice towers. Alternatives of less visual impact should be fully considered and modifications to siting, location, materials and height in the design of the transmission line should be made to avoid or minimize any adverse impacts to these open-space properties and their public values. If the SCC certificate is issued, the permit should require implementation of all industry best practices, including, but not limited to (1) minimal removal of vegetation through use of a clearing plan and (2) use of non-reflecting or de-glared conductors and dulled steel for towers and structures."

We appreciate Dominion Virginia Power's response to our concern regarding the removal of vegetation and have no further comments on that. However, with regard to our request for consideration of the use of low reflective visual mitigations, we would like to point out that we have worked with other utilities, specifically the Appalachian Power Company (ACP) who has implemented these visual mitigations in the construction of electric transmission lines. ACP has used a darkened or low-reflective treatment applied to the finish of galvanized steel lattice towers to reduce the visual presence of the structures in scenic areas. They have also applied a non-specular finish to reduce glare and mitigate visual impacts to the conductors. These significant and proven visual mitigations demonstrate that it is possible to make changes to the design and materials of electric transmission lines in some cases.

VOF would ask that Dominion Virginia Power consider any measures that might minimize the visual impacts to the important scenic, and cultural resources of this region. VOF hopes to continue to work with Dominion

i Virginia Power in a collaborative way to ensure that the Commonwealth's investments in the protection of open ^ space are not jeopardized in any way. Thank you again for the opportunity to comment. •• @ yj Martha Little @ © ea

From: Charlotte P McAfee (Services - 6) rmailto:[email protected] Sent: Thursday, April 14, 2016 9:45 AM To: Wellman, Julia (DEQ)' Cc: Little, Martha (VOF); Amanda M Mayhew (VirginiaPower - 6); G. W. Jackson (VirginiaPower - 6) Subject: RE: Cunningham-Dooms 500 kV Transmission Line, PLIE-2016-00020 / DEQ #16-0495

Julia, Thank you for providing Dominion Virginia Power (Dominion) the opportunity to respond to the Virginia Outdoors Foundation's (VOF) letter dated March 30, 2016 regarding Dominion's Dooms-Cunningham 500kV transmission line rebuild project proposed in State Corporation Commission Case No. PUE-2016-00020.

VOF raised concerns regarding vegetation removal and use of galvanized steel towers. Dominion's response to VOF's concerns is below.

1) Vegetation removal

• The rebuilding of this line will not require additional tree clearing outside of the existing right-of- way, which varies in width. However, as required by North American Electrical Reliability Corporation, trees that are determined to be "danger trees" (any tree alive or dead that could fall within ten feet of the line) will be removed. Access to structures within the right of way will include minor improvements through the use of mats or gravel. Landowners will be notified of work; on their property before the construction starts. Dominion's clearing methods are described in greater detail in Section II.A.5 of.the Appendix (p. 38) and Section 2.Kof the DEQ Supplement (p. 10-11) filed with the Application.

2) Materials for towers and structures

• Dominion has proposed to use its typical transmission line materials and structures to rebuild this line. The existing steel lattice towers (brown structures) proved to be inferior and degraded greatly over time. Dominion now uses galvanized lattice towers for all 500 kV lines. The galvanized steel is used throughout the industry and has proven to be the best type of finish for lattice towers. Depending on environmental conditions, galvanized steel lattice structures take between 24 and 48 months to achieve the typical dullness that is seen on older galvanized steel structures. Using galvanized steel towers provides the greatest protection against the elements and ensures that structures can meet the 40-50 year lifespan with minimal maintenance.

Dominion does not believe that the additional cost and potential decrement in structural integrity posed by the use of non-reflecting or de-glared conductors and dulled steel for structures, as requested by VOF, is appropriate.

Dominion appreciates the opportunity to provide comments on the VOF letter. If there are any questions on this project please feel free to contact me.

2 Thank you, J Charlotte McAfee ... • • ©

& Charlotte P. McAfee Senior Counsel, Law Department ~jj Dominion Resources Services, Inc. ^ 120 Tredegar Street, Riverside 2 Richmond, VA 23219-4306 [email protected] 804.819.2277 (office) ' 804.310.2183 (cell)

From: Wellman, Julia (DEQ) rmailto;[email protected] Sent: Tuesday, April 05, 2016 10:26 AM To: Charlotte P McAfee (Services - 6) Subject: FW: Cunningham-Dooms 500 kV Transmission Line

Please see the attached letter from the Virginia Outdoors Foundation.

Does Dominion have any comments or response to VOF regarding its concerns on the scenic viewshed and galvanized steel lattice towers?

Julia Wellman Environmental Impact Review Coordinator Department of Environmental Quality 629 E Main Street Richmond, VA 23219 (804) 698-4326 [email protected] www.deq.virqinia.qov

**** For program updates and public notices, please subscribe to the OEIR News Feed.****

From: Little, Martha (VOF) Sent: Friday, April 01, 2016 3:34 PM To: Wellman, Julia (DEQ) Cc: Hallock-Solomon, Michael (VOF); Fuller, Brian (VOF) Subject: Cunningham-Dooms 500 kV Transmission Line

Julia, Please see VOF's comments on the following project attached:

3 V/TDD'(804) 236-3624 Randall P. Burdette Department ofjiviation FAX • (804) 236-3635 Executive Director 5702 Gulfstream Road .Richmond, Virginia 23250-2422 ISO 9001:2008 Certified IS-BAO Registered

Transmitted via Email

March 22, 2016

Ms. Julia Wellman Department of Environmental Quality Office of Environmental Impact Review 629 East Main Street, Sixth Floor Richmond, VA 23219

Re: Cunningham Dooms SOOkV Transmission Line Rebuild PUE-2016-00020 Project Number: 16-049S

Dear Ms. Wellman:

Thank you for the opportunity to comment on the Cunningham Dooms SOOkV Transmission Line Rebuild project in Albemarle, Augusta, and Fluvanna counties. The closest public-use airport to the proposed project location is the Eagle's Nest Airport outside of Waynesboro.

To insure that the proposed facility would not create a hazard to air navigation for the airport, given that some of the new structures are of a greater height, the applicant should confirm with FAA that Part 77 safety areas, especially the horizontal surface, are not penetrated through the filing of Form 7460-1. FAA's Washington Airports District Office can be contacted at 703-661-1354 for additional information.

The design of the transmission line and station rebuild must prevent interference with pilots' safe ingress and egress at the airport. Operational activities along the transmission line should not pose a hazard or impediment to pilots using the airport. Such hazards or impediments include interference with navigation and communication equipment, interference with existing and planned approach procedures for all aircraft published for or by the airport, and glare from building materials.

• Please let me know if you have any questions on our comments.

Sincerely,

Susan H. Simmers Airport Services Division

ec: John Trissel, Eagle's Nest Airport

100 DOAVAS 20160322 DEQ16-049S Cunningham Dooms Trans m a a © Planning District Commission m m Regional Vision • CollaboratlvB Leadership* Professional Service

April 21,2016

Valerie A. Fulcher CAP-OM, Environmental Program Specialist Pcpattment-orEhvirOninenlal Quality Environmental EnhanceineiU - OPfice of Environnienlal Impact Review 629 E Main St.; 6lh;Floor Richmond, VA 23219

Document Type: SCC Application - OEIR Review Request Response Project Sponsor State Corporation Commission Project Title: Cunningham-Dooms 500 kV Transmission Line Rebuild Location: Albemarle, Augusta, & Fluvanna Counties Project Number: DEQ #16-049S

Dear Ms. Fulcher: .

The Thomas Jefferson Planning.District Commission is in receipt of your OEIR Review Request for the SCC Application DEQ # 16-049S referenced above. The TJPDC has no environmental issues or concerns with the rebuild project as proposed. But, as the Intergovernmental Review Agency for Albemarle and Fluvanna Counties, we do suggest the consideration of designing structures that will allow additional lease use for broadband internet transmission and/or service uses. Providing broadband supply lines or antennas into the rural areas where this transmission line is currently located would provide an opportunity to rural areas of our counties with services that are currently unavailable and would do so without additional structures having to be constructed that could cause unnecessary environmental impacts.

Both counties are currently exploring ways to reach underserved rural areas of their counties with essential broadband utility service and this cooperative use of existing structures could provide this means in an economical and environmentally positive manner.

Thank you for this consideration and please do not hesitate to call on me for further information.

CharlesT. Bpyles,II Executive Director

Cc: Liz Palmer, Chair, Albemarle County Board of Supervisors Rick Randolph, Albemarle County Board of Supervisors Steve Nichols, Fluvanna County Administrator

City of Charlattesville Albemarle County Fluvanna County Sreene County toulsa County Halson County 401 East Water Street • Post Office Box 1505 « Charlottesville, Virginia 22902-1505 Telephone (434) 979-7310 • Fax (434) 979 1597 • Virginia Relay Usersi 711 (TDD) • [email protected] * web: www.tjpdc.org COUNTY OFAUGUStil VA. 7 BO^RD pF'SUPERVISORS^^"^ MARSHALL W. PATTIE GERALD W. GARBER- , North River Middle River .

TRACY C. PYLES, JR. WENDELL!. COLEMAN Pastures TERRY L. KELLEY, JR! . WaYne - Beverley Manor MICHAEL Li.SHULL CAROLYN S. BRAGG TIMGTHYJK^HrrZGERyLpy.COUNTY ADMINISTRATOR" Riverheads' ' South River i . AUGUSTA COUNTY GOVERNMENT CENTER " ' P.O. BOX 590, VERONA,- VA 24482-0590 April 28, 2016; ; (540) 245-5610 FAX (540) 245-5621 Julia Wellman- ^ r 1 [email protected] — < • ' -i Coordinator , Department of Environment Quality Office of Environmental Impact Review ^ ' 629 E. Main St., 6th Floor Richmond, Virginia 23219, " , , •' ;

Document Type: SCC Application . ;r . ~ i , - Project Sponsor: State Corporation Commission , Project Title: Cunningham-Dooms 500 kV Transmission Line Rebuild r:l • Project Number: DEQ #16-0493 , ,

Dear Ms. Wellman: . x ^ • ' ' », ^ • Augusta County is included in the service area upgrade for the Cunningham-Dooms Transmission Line Rebuild. The County is also fortunate to have received a Virginia Telecommunication Planning Initiative (VATPI) Grant to develop a plan that will lay the groundwork to improve and expand internet service in the area.) Please, accept this correspondence as a comment for the DEQ #16-049S project. - Our telecommunications plan consultant is tasked with providing professional . recommendations and network alternatives that are feasible and achievable for the community. Part of this task is to identify existing infrastructure and providers that may consider public-private partnerships to expand internet service into the County. The Cunningham-Dooms Transmission.Line Rebuild project will be able to assist in this task by providing structures that will allow additional lease use for broadband internet : transmission and/or service uses. Multiple uses of the same easement will allow for less environmental impact on the rural area. ,

i. ' : Thank you for this consideration and please do not hesitate.to call on me for further information.

Sincerely,

Timothy K. Fitzgerald County Administrator Wellman, Julia (DEQ) a Wi From: Rita Whitfield & Sent: Tuesday, May 03, 2016 4:02 PM © To: Wellman, Julia (DEQ) © Subject: RE: Intergovernmental Review Response for Dominion Transmission Line asking to include Broadband

Ms. Wellman:

I spoke with our Executive Director, Bonnie Riedesel, and she said she had no response regarding the Cunningham- Dooms line.

Thank you, Rita

—Original Message— From: Wellman, Julia (DEQ) [mailto:[email protected]] Sent: Tuesday, May 03, 2016 2:28 PM To: Rita Whitfield Subject: RE: Intergovernmental Review Response for Dominion Transmission Line asking to include Broadband

Hi Ms. Whitfield,

Does the PDC plan to respond to the environmental review regarding the Cunningham-Dooms line? If so, I need your comments by today. Thank you.

—Original Message— From: Rita Whitfield [mailto:[email protected]] Sent: Thursday, April 28, 2016 10:03 AM To: Wellman, Julia (DEQ) Subject: RE: Intergovernmental Review Response for Dominion Transmission Line asking to include Broadband

Hi Ms. Wellman:

Do you have a copy of the application that you can send me? CIRP means "Commonwealth Intergovernmental Review Process."

Thanks for your help! Rita

—Original Message— From: Wellman, Julia (DEQ) [mailto:[email protected]] Sent: Thursday, April 28, 2016 10:00 AM To: Rita Whitfield Cc: Fulcher, Valerie (DEQ); Walsh, Patty (DEQ) Subject: RE: Intergovernmental'Review Response for Dominion Transmission Line asking to include Broadband

Ms. Whitfield, l