DNR Exhibit (WAR-1) BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND
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1 DNR Exhibit (WAR-1) BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND In the Matter of the Applications: (1) to Establish the ) Overall Need for the Construction of a New Transmission ) Line Known as the Mid-Atlantic Power Pathway (MAPP) ) Project; () to Modify the CPCN in the Case ) To Construct an Already Approved Second 00 kv Circuit ) Case No. 1 On New Support Structures across the Potomac River; ) () to Modify the CPCN in Case No. to Construct a ) Second 00 kv Circuit Between Chalk Point and Calvert ) Cliffs, Maryland and to Replace Certain Existing Structures ) For the Existing 00 kv Circuit in Calvert County ) DIRECT TESTIMONY OF WILLIAM A. RICHKUS ON BEHALF OF THE MARYLAND DEPARTMENT OF NATURAL RESOURCES POWER PLANT RESEARCH PROGRAM Tawes State Office Bldg., B- Annapolis, MD 1-0- December, 00
2 Q. PLEASE STATE YOUR NAME, OCCUPATION, AND CURRENT POSITION. A. My name is William Richkus. I am Director of the Ecological Sciences and Applications Division at Versar, Inc., the Biology Integrator contractor to the Maryland Department of Natural Resources (DNR) Power Plant Research Program (PPRP). My expertise is in the fisheries biology, resource management, and impact assessment, both terrestrial and aquatic. A statement of my educational background, occupational history, and professional qualifications is provided as Appendix A to this testimony. Q. HAVE YOU PARTICIPATED IN OTHER PROCEEDINGS TO DETERMINE ENVIRONMENTAL IMPACTS? IF SO, WHAT WAS THE NATURE OF YOUR ROLE? A. Yes. I am the Program Manager for Versar s Biology Integrator contract and have provided impact assessment support to PPRP for over thirty years. I have authored or contributed to numerous impact assessment reports over that time period and have served as an internal technical reviewer of sections of Environmental Review Documents (ERD) and PSC testimony that my staff have prepared for PPRP. I have also served as an expert witness on behalf of Maryland DNR in FERC hydroelectric licensing proceedings as well as in PSC CPCN proceedings. Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? A. The purpose of my testimony is to present my assessment of the potential scope of impacts to the aquatic resources of Chesapeake Bay that could result from the segment of the proposed MAPP project that would cross Chesapeake Bay. Q. PLEASE SUMMARIZE YOUR FINDINGS ON WHAT NATURAL RESOURCES THAT WOULD BE AT RISK FROM CONSTRUCTION OF THE MAPP PROJECT THAT WOULD EXTEND ACROSS THE BAY.
3 A. Important aquatic resources in the Bay, such as oysters, blue crabs, various fish species and submerged aquatic vegetation (SAV) could be adversely impacted as a result of environmental changes caused by environmental modifications resulting from the installation and the presence of the line itself, (e.g., heat and EMF). Q. WHAT ARE THE DETAILS OF THE PROPOSED BAY CROSSING SEGMENT OF THE MAPP PROJECT? A. Pepco has proposed crossing Chesapeake Bay via a set of submarine cables that would require up to a 00-foot right-of-way (ROW). Pepco has indicated that cable spacing is equal to water depth. Thus at 0-foot depths, the ROW would be up to 00 ft wide to accommodate the proposed cables. This width would narrow in shallower water as the cables approached the shoreline. Pepco has not submitted siting information with its MAPP Need Application. Therefore, I cannot determine the exact location. Based on Pepco's public statements, the general description of the MAPP project, and other information provided to PPRP, it is my understanding that the submarine crossing will most likely be between Calvert Cliffs and Taylor s Island. Other routes in the same general vicinity have been discussed, including continuing the submarine cables along and under the Little Choptank River. Q. HOW WOULD THE CABLES BE INSTALLED? A. Given the distance across the bay and the depths that will be encountered, it is anticipated that the submarine cables would be installed in trenches in the bottom sediment created by water jetting or mechanical plowing. Pepco described the techniques that would be used in response to DNR Data Request - of these proceedings. The cable could be installed in a trench up to -1 feet deep depending on local sediment characteristics. During the plowing and installation process, the bottom sediment will be displaced from the trench and potentially suspended in the water column, during up to six passes across the entire Bay.
4 According to Pepco's material, it is expected that the material displaced by the plowing operation would subsequently fill in around the cable in the excavated trenches over time as a result of normal sedimentary processes. Depending on the trenching method used and the degree to which the sediment is fluidized or dispersed by currents, it is possible that mounds of displaced sediment would remain along the sides of the trench for an extended period. Q. HOW WILL THIS CROSS-BAY MAPP SEGMENT AFFECT ENVIRONMENTAL CONDITIONS IN THE BAY? A. There will be a number of environmental modifications during installation that would be short-term in nature. Sediment will be removed from the cable locations within the ROW and be deposited in adjacent areas. Sediment plumes created by the trenching activity may result in sediment transport and deposition in other locations, release of sequestered nutrients, and reductions in dissolved oxygen. The sediment plumes would also result in localized increases in turbidity and total suspended solids. Longer-term impacts will result from the placement and operation (i.e., electrical transmission through the cables) of the cables, including the creation of a physical barrier to movement by some species, locally high electromagnetic fields near the cable, and strips of permanently heated sediment across the width of the Bay. A particular concern is that continuously operating buried cables reach temperatures of 0 degrees C and can create zones of elevated sediment temperature significantly above ambient conditions tens of feet from the cable, depending on sediment thermal characteristics. Q. WHAT ECOLOGICAL RESOURCES MAY BE AT RISK FROM THIS DISTURBANCE? A. The Chesapeake Bay is inhabited by a wide range of species of great importance to society as well as to the entire Chesapeake Bay ecosystem. Many fish species, as well as benthic species such as Blue Crab, routinely migrate up and down the Bay,
5 for example to and from spawning, nursery or feeding locations. Most well-known is the striped bass, which spawns in Bay tributaries in the spring (March - May), with juveniles using the entire Bay as nursery area before the migrate to the ocean at a later age. Other fish species, such as Atlantic Menhaden, spawn in the Atlantic Ocean, with their juveniles entering the Bay during the summer and using Bay waters as a nursery area. Such juveniles are both an important consumer species of lower trophic organisms and a food source for larger fish and birds. Sensitive benthic habitats such as oyster beds are present throughout the Bay. They are at the base of many food chains, and are sensitive to contaminants as well as the chemistry (e.g. amount of dissolved oxygen) of the water. The Bay s oyster population, which is severely depressed, occupies hard bottom areas. In the middle Bay region, male Blue Crabs bury themselves in the bottom sediment and hibernate during the winter. Females migrate to areas to the south in the fall. Submerged aquatic vegetation (SAV) forms critical spawning and nursery habitat for many Bay species. SAV beds have decreased in extent over the Bay, and their preservation, expansion, and restoration is an important Bay management priority. The Chesapeake Bay is on the Atlantic Flyway, and serves as the overwintering refuge for numerous species. Of particular concern with respect to the proposed underwater cable would be open water species such as diving ducks. Hundreds of thousands of ducks overwinter in the Bay and its tributaries and wetlands from October through March. Species such as Long-Tailed Ducks and Scoters feed on oysters and clams, sometimes in free-floating flocks of hundreds of birds. Other species concentrate in near shore areas. Key habitat areas and the effects of disruption are not well known, but some experts are concerned by indications that the populations in the Bay have declined in recent years.
6 Q. WHAT ARE THE SHORT-TERM EFFECTS FROM CONSTRUCTION? A. Construction will result in removal of sediment from trenched areas and deposition of that sediment in adjacent habitat. Such actions will dislodge and disturb benthic organisms in the sediment and likely cause direct mortality. Deposition may result in smothering of some sensitive benthic organisms. Increased turbidity and decreased dissolved oxygen that may occur in the turbidity plume during construction may harm planktonic organisms and fish. Although there are no significant biological resources in the deep center portion of the Bay (below 1m depth), because it frequently experiences very low dissolved oxygen, re-suspension of sediments from this area could exacerbate oxygen depletion. Resuspension of nutrients as a result of trenching could increase nutrient levels in the water column, contributing to algal blooms that are the primary cause of oxygen depletion in the Bay. Q. WHAT ARE THE POSSIBLE LONG-TERM EFFECTS FROM OPERATION OF THE CABLE? A. Transmission of electricity results in heating of the cable, and a continuous release of this heat to the surrounding sediment. The typical operating temperature of a submarine cable will be 0 degrees C (Pepco response to DNR Data Request -, Appendix C) and each cable, based on estimates for other installations, will generate s of watts of heat per linear foot. The spatial extent of elevated temperatures that may result from cable operation is dependent on the sediment composition, but increases in temperature of or more degrees C are possible at distances of 0 to 0 ft from the cable (based on models for the SMECO Patuxent River crossing), that is at the surface for a cable buried less than 0 feet deep. Regions directly adjacent to the cable would be uninhabitable and the increased temperature at greater distances could affect normal behavior and life cycles of some species. The heat generated by the - cables distributed across the width of
7 the right of way will accumulate and create an anomalously warm strip of bottom hundreds of feet wide. Biological effects of elevated temperature may include changes in metabolism, shifts of spawning periods, or attraction to/avoidance of the warm habitat. Electric transmission also creates electromagnetic (EMF) fields which are known to affect the behavior of some fish, such as eels, rays and sharks. The creation of irregular bottom topography in an area of the Bay bottom that is normally flat might affect the movements of species, such as blue crabs and fish species, through the area. Q. HOW COULD ANY IMPACTS PROJECTED FROM THE BAY CROSSING BE MITIGATED OR AVOIDED? A. Given that some environmental perturbations from cable installation are shortterm, timing of construction so that it takes place when sensitive species are least likely to be present would be critical. Establishing locations of particularly important habitats, such as oyster beds and SAV prior to installation could allow for routing to minimize impacts. However, based on the biological resources at risk and likely affects of the cable, there is potential for permanent impacts to the aquatic environment that may be substantial, in which case a consideration of alternate routes that would avoid the Bay crossing would be appropriate. However, at this time Pepco has not indentified such alternative routes in a way that would provide any basis for making a comparative analysis of impacts. Q. DOES THIS COMPLETE YOUR TESTIMONY? A. Yes.
8 APPENDIX A WILLIAM A. RICHKUS, Vice President, Operations Manager, Versar, Inc., P.M.P. Education: Ph.D., Oceanography, Graduate School of Oceanography, University of Rhode Island, l M.S., Oceanography, University of California (San Diego) Scripps Institute of Oceanography, l B.S., Zoology, University of Rhode Island, l Experience: Versar yrs Others yrs Professional Background: Dr. Richkus has for 0 years served as Program Manager of Versar's Maryland Department of Natural Resources Power Plant Research Program's Biology Integrator contract, and has supported PPRP for years in numerous capacities. He led the proposal effort that resulted in Versar being awarded a -year continuation of this support contract extending to the year 0. In his management role, he has technical, fiscal and administrative oversight responsibility for all projects and tasks conducted for PPRP, funded at a level of about $00,000 annually. The types of projects that he supervises include the design, implementation and interpretation of aquatic and terrestrial studies of impacts of existing or proposed power generation (fossil fueled, nuclear, hydroelectric, and wind power) and transmission facilities, meeting applicable licensing and permitting support requirements of PPRP (e.g., NPDES and 0 permits, CPCN), and contributing to program strategic development and planning. Areas of special technical expertise that Dr. Richkus contributes to the program include fisheries biology, fisheries management and hydroelectric facility impact assessment, licensing, CWA Section 1(a) and 1(b) compliance, and mitigation. He has been extensively involved in PPRP projects that investigated power generation impacts to major resource species in the Chesapeake Bay, including American shad, striped bass, blue crab and oyster, as well as fresh water aquatic communities in Chesapeake Bay tributaries. He has also directed a wide range of terrestrial and wetlands ecosystem studies and assessments within the Chesapeake Bay watershed to meet PPRP requirements, ranging from site-specific wetlands delineations to cumulative impact assessments on watershed and landscape levels. Aquatic studies he has designed and managed have ranged from ichthyoplankton, zooplankton, benthic and fish community field studies, to complex population modeling of consequences of ichthyoplankton entrainment on adult fish stocks. He has participated on behalf of PPRP in NRC licensing activities for the Calvert Cliffs nuclear power plant, in numerous Maryland Public Service Commission proceedings for new proposed generating facilities in the state (including review of utility submittals, preparation and presentation of testimony, and preparation of certificate articles), and in FERC licensing proceedings for the Conowingo hydroelectric facility as well as numerous small-scale hydroelectric facilities in the state. He is a nationally recognized expert in assessment of impacts to fish populations from impingement and entrainment and CWA Section 1b compliance, having authored several book chapters and symposium volume sections on these topics. Dr. Richkus also recently served as Project Manager of a project funded by the Maryland Department of Natural Resources to conduct an ecological risk assessment and prepare a Programmatic Environmental Impact Statement addressing a proposal by the states of Maryland and Virginia to introduce the Asian oyster, Crassotrea ariakensis, into the Chesapeake Bay and seven additional alternative oyster restoration approaches. He recently served as Project Manager on a project funded by the New York Power Authority to prepare five white paper synthesis reports addressing various technologies that may be feasible for use in the St. Lawrence River to either guide downstream migrating silver eels to passage facilities or to capture facilities from which they would be transported downstream of the FDR
9 Hydroelectric project. Dr. Richkus currently serves as Corporate Principal and Manager of a technical support contract from the NOAA Chesapeake Bay Office. Under this contract, Versar provides on-site staffing of technical positions and also conducts studies and analyses relating to Chesapeake Bay habitat and natural resources. Dr. Richkus contributed to design of studies and development of data management approaches. He recently supported the City of Newport News and the Regional Raw Water Study Group in assessing and mitigating potential fisheries impacts from the highly controversial King William Reservoir project. For Mirant s Kendall power generating station in Cambridge, Massachusetts, Dr. Richkus provided expert testimony in the review of a draft NPDES permit and Clean Water Act Section 1a variance for the facility issued by EPA Region 1 and the Massachusetts Department of Environment. He was requested by Mirant to review the manner in which data from scientific publications on anadromous river herring that he authored were used in developing temperature limits incorporated into a draft permit facility, and also to provide general overall comments on the permit. Dr. Richkus was co-principal Investigator on a recently completed project funded by the Cooperative Fisheries Program of NOAA. The purpose of the study is to evaluate the use of remote sensing technology to develop indices of essential fish habitat for important Atlantic coast commercial fish species. He was co-principal investigator on a contract from the U.S. Department of Interior Minerals Management Service (MMS) project to assess the ecological consequences of removal of oil and gas rigs from the Gulf of Mexico. Dr. Richkus served as Corporate Principal and co-principal Investigator on a recreational fishery creel survey over 0 miles of the Delaware River and Estuary. Dr. Richkus also serves as Corporate Principal on a two year contract from the MMS to assess the fisheries habitat value of sand shoals offshore from Maryland and Delaware. Dr. Richkus served as Project Manager of several projects conducted for the Delaware Department of Natural Resources and Environmental Control relating to CWA 1a and 1b compliance of several Delaware power generating stations. This work entailed characterizing the types and magnitudes of impacts from entrainment and impingement at these generating facilities to aquatic resources and the design of sampling methods, procedures and schedules that would be required by facilities requesting water withdrawal and NPDES permits. He served from 11 to 1 as Deputy Program Manager on Versar's NEPA support to the Federal Energy Regulatory Commission. In this role, he directed the preparation of Environmental Assessments and Environmental Impact Statements or sections of such documents for the licensing or relicensing of hydroelectric facilities in states throughout the country. Publications: Dr. Richkus has authored or co-authored publications in refereed journals and symposium volumes, has authored three book chapters, and has authored or co-authored more than one hundred technical reports.
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