Here is my submission for the National Parks Service.

While I believe the National Parks Service (NPS) is correct in requiring PPL and PSE&G to perform their due diligence in the form of an Environmental Impact Statement (EIS), I also believe that additional steps should be taken.  If the National Park Service is willing to consider several options outside its jurisdiction, including the original proposals of Route A and C, I believe that the NPS should do a complete valuation, including:
 
     – a technical examination of the current and future need of the line based on a known reduction in electric usage and challenging PJM to prove the new line is still required*
     – an evaluation of building a power plant within New Jersey to service that area directly, creating local jobs and improving local economies**
     – an evaluation of the raptor migration corridor, which all 3 lines will impact***
     – a cost analysis on the displacement cost for people, property value depreciation, and the tax revenue loss in townships for the areas along all 3 proposed paths
 
I do not believe that the decision for an entire route should be made on the EIS study and public input alone for 4.18 miles of public land.  If the NPS pushes for only a provincial EIS and public input without truly examining the cost to Pennsylvania residents outside the park’s jurisdiction, they are performing a disservice to the state and potentially causing a conflict of interest between the Federal Government and its citizens.  Basing the permit’s outcome without a full evaluation of all the lines or considering the additional alternative of perhaps building a power plant in New Jersey, the NPS could force its same governing body to utilize eminent domain under the NIETC act to complete this line in another location.  This act would inspire one to believe that the Federal Government as a whole is out to protect its interests solely without concern for its residents.
 
Pennsylvania has a long standing tradition of being the Keystone State.  While this nomenclature was born from democracy and our geographic setting within the original union, this name has a very different meaning for today’s publicly trading utility companies.  Pennsylvania has become the state through which all energy passes.  Land in 52 out of 67 counties in Pennsylvania can be taken via eminent domain through the National Interest Electric Transmission Corridor Act.  There is a clear disconnect when land in Pennsylvania can be used to service another state against its resident’s wishes under the guise of “public interest” when the state in need help refuses to help itself.

I strongly urge the NPS to fully evaluate all lines and all aspects of this argument before making a decision.  If that is not possible, I believe the best course of action would be to allow the Route B line to proceed through the park along the existing route.  PPL and PSE&G have stated that they will take extra precautions around the environment and going along the existing line would make the most sense.
 
*Wall Street Journal, November 21, 2009 “Weak Power Demand Dims Outlook”
   http://online.wsj.com/article_email/SB125876259256658319-lMyQjAxMDI5NTI4MTcyNjEyWj.html
*Wall Street Journal, January 2, 2010 “Two-State Power Line Is Put Off”
   http://online.wsj.com/article/SB126239144004113055.html
 
**Star News Online, December 23, 2009 “Nuclear power industry a boon to local economy”
   http://www.starnewsonline.com/article/20091223/ARTICLES/912239954?Title=Nuclear-power-industry-a-boon-to-local-economy
**UMass and Center for American Progress-PERI, June 18, 2009 “The Economic Benefits of Investing in Clean Energy”
   http://www.peri.umass.edu/economic_benefits/
 
*** Kittatinny-Shawangunk National Raptor Migration Corridor Project
   http://www.raptorcorridor.org