The National Environmental Policy Act (NEPA) requires that all federal agencies prepare detailed environmental impact statements (EIS) for federal actions significantly affecting the quality of the human environment.

Project scoping is a critical part of the NEPA process whereby agencies and the public are given the opportunity to point out potential key impacts and resources to be avoided in planning the project and addressing alternatives.

Certainly these inputs, as well as specific letters from the S.C. Department of Natural Resources dating back to 2006, citing avoidance of key resources and recommending following the SCE&G alignment up Highway 17 from Mount Pleasant, made Central Power aware of key critical resources in the proposed alignment corridors and the overwhelming recommendation to solve the McClellanville problem from the south.

Despite this input, they chose to move forward by creating a Draft EIS (DEIS) dismissing the southern alternative and keying in on much more environmentally damaging alternatives that include crossing the Santee Delta and other very sensitive habitats.

The NEPA process was designed to be a valuable decision-making tool and can be if the process is followed in an open manner without favored alternatives pre-selected before entering the process. Such treatment (not uncommon) in NEPA processes, just writes the document from the back forward. That is, instead of a decision-making tool, it is written to justify a pre-selected alternative or set of alternatives.

The need for the project as stated in the DEIS is simply ". to address system reliability and power quality issues resulting from the current use of the aging distribution line."

This need statement allows exploration of a number of alternatives that warrant detailed consideration.

However, the very title of the DEIS "McClellanville 115Kv Transmission Project," and the introductory statement that "Central Electric and Berkeley Electric propose to construct, operate, and maintain a new 115 kilovolt (kV) electrical transmission line and substation in eastern South Carolina near the town of McClellanville" bias the whole NEPA process by eliminating other alternatives to satisfy the basic project purpose.

Besides thorough vetting and comparative environmental impact analysis of a southern route solution, the DEIS is lacking key information needed for full environmental analysis on the limited alternatives in the document. This includes missing GIS information on plantations, long-leaf pine restoration sites, critical habitat designations for endangered species, etc.

In light of all of these deficiencies, it seems prudent to not proceed to the Final EIS stage, but rather to go back and replace or supplement the Draft EIS.

Steve Gilbert

Special Projects Manager

South Carolina Wildlife Federation

Key Court

James Island