With a federal decision approaching for the SunZia Southwest Transmission Project and the Department of Defense objecting to the routing of the project, SunZia manager Tom Wray recently made an impassioned argument for “a legitimate third-party scientific review” to dispel objections to routing his project across the extension of the White Sands Missile Range.
Under pressure from Sen. Martin Heinrich, the Massachusetts Institute of Technology’s Lincoln Laboratory has undertaken this for him.
This is not the first time SunZia and its federal oversight agency, the Bureau of Land Management, have appealed to special studies to quash objections to the massive 500-mile-long project.
A feasibility study was used to eliminate serious consideration of routing the project along the Interstate 10 corridor through Tucson. This was conducted by the Environmental Planning Group, which has a long pre-existing business relationship with SunZia’s proponents but managed to become the BLM’s environmental review contractor for the project through a recommendation by SunZia itself.
This company assisted in a similar study to establish that burying the proposed extra-high-voltage lines on selected route segments would not be economically feasible.
However, despite allowing ad hoc feasibility studies that support the proposed project, the BLM did not allow significant findings in a third-party study conducted for the closely related High Plains Express transmission proposal to be included in SunZia’s Environmental Impact Statement.
Those findings indicate that, in the absence of a carbon tax, the BLM’s energy forecast contains two to three times as much renewable energy as would be financially viable. These findings are based on real world market factors, not on “intentions” or public relations spin, and show that much higher levels of fossil-fueled energy would be required to provide reliable and cost-competitive energy delivery.
Four Arizona groups submitted relevant findings of the study to the BLM eight times over the two-year period prior to the release of the final EIS, only to see these findings repeatedly ignored or dismissed in federal environmental review documents.
The BLM’s gross overestimation of renewable energy development obscures a proportional underestimation of electrical generation from natural gas resources. These Arizona groups also repeatedly submitted relevant and credible information, in one case from SunZia’s own statements to the Federal Energy Regulatory Commission, on the high likelihood that electrical generation from natural gas resources would play a much greater role in energy development along the proposed lines than was acknowledged in the EIS. This information was also dismissed by the BLM.
SunZia and the BLM used this gross overestimation of renewable energy development to justify the necessary capacity of the proposed lines, the resultant routing of them through previously undisturbed lands in Arizona and New Mexico, and the elimination of other more appropriately scaled and planned transmission proposals as possible alternatives.
By selectively employing feasibility studies to favor SunZia’s interests, the BLM has violated federal regulations regarding neutral oversight and assessment of environmental effects. Last November, Arizona Reps. Ron Barber and Ann Kirkpatrick wrote to Secretary of Interior Sally Jewell requesting that the dismissed feasibility study and other relevant information submitted by Arizona groups be considered.
If this information is not incorporated into the analyses of the EIS, litigation will be the only option available to enforce federal law prohibiting arbitrary and capricious decisions, and to restore integrity to the environmental review process.
Litigation should not be necessary to get fundamental information included in an environmental impact statement. In this case, it may be.
We welcome any support or suggestions on how to proceed.