Terrapin Springs Farm is committed to protecting our natural heritage — the woodlands and forests, our wetlands and all the animals and plants they support, and our water and air. Unfortunately, not everyone in our community supports these goals. Our letter to our community:

No one can argue that Dominion Energy’s Buggs Island-Plywood 115kV Electric Transmission Rebuild Project is not a needed upgrade to the 26-mile line between the Buggs Island substation and the Plywood substation. Unfortunately, Dominion’s questionable planning will do unnecessary harm to local landowners, our community, and the environment.

When Dominion’s forestry representative stopped by to talk with us about their plan for tree removal associated with the line rebuild, they mentioned they might have to cut a few trees. Later, after the forestry representative marked the tress, we learned they planned to cut down more than 460 trees in a 1200ft stretch outside the easement through our property — impacting our wetlands, creating future erosion, and leaving the downed trees as an eye sore, and the land unusable.

We have reviewed the Joint Permit Application for the project, and note that the permit covers activities “entirely within the existing transmission line right of way (ROW),” “will minimize additional disturbance from the project,” and that “permanent impacts … have been avoided to the greatest extent possible.” The permit further states work will be performed within existing, maintained ROW and additional clearing will be limited to danger trees, limbing, and those required to be removed for access to structures.

The permit does not include or mention an environmental assessment for activities outside the ROW and the environmental impacts of removing the large volume of trees envisioned by the planned tree removal. As such, we do not believe the tree removal impacts have been properly assessed.

We understand Dominion’s rationale that all trees that could possibly fall on the transmission line need to be removed. However, we assert this policy is not supported by safety analysis, science and engineering, environmental assessment, or Dominion’s own practice over the past 55+ years.

Looking at the broad environmental impacts, we extrapolated our tree loss across the entire 26-mile project and it appears Dominion plans to remove between 50,000 and 100,000 trees adjacent to the easements bordering on forests. Science tells us that the loss of these trees will eliminate the removal of 3 million – 5 million pounds of the most dangerous greenhouse gas from our local air each year, as much as 150 million pounds of carbon dioxide over the life of these trees (the equivalent of the CO2 emissions from all autos and trucks in Halifax County for a year) – harming our local air quality and agricultural production.

If Dominion’s policy of tree removal associated with the project were absolutely necessary, we would be forced to begrudgingly accept it. However, we do not believe it is necessary or even smart policy. When a project like this has such a significant impact, an environmental assessment should address ways to mitigate the impact, and the local community should be consulted. We can find no evidence of an assessment or consultation regarding the tree loss. The impact goes beyond greenhouse gases. Tree removal creates erosion and degrades our wetlands; and damages structures like houses and out-buildings near the easements. Dominion’s actions effectively increase the easements across properties by more than 60ft beyond current easement agreements, and impacts the landowners use of the property.

Dominion’s argument for tree removal is that the trees impose a safety risk to the transmission lines should a tree fall on a line. While this is a risk, it is an extremely remote possibility. While trees are a major problem for local distribution lines with much smaller easements, data indicates that they are not a significant risk for transmission lines like the Buggs Island-Plywood line. We can find no evidence that a tree has fallen on the existing line in the current easement in its 55+ years existence. Research in the community indicates the only local problems have been due to extreme weather directly impacting the poles, such as tornadoes.

Safety engineering cannot assure zero risk in anything. The risk-reward scenario becomes a tradeoff between the probability of a tree falling on a line and the cost of restoring service, vs. the cost of tree removal, the potential damage to landowner property, the wetlands ecosystem, and the long-term environmental impact on our community.  While the accrued benefits to Dominion in terms of line repair may be in the range of zero to hundreds of thousands of dollars, the impact on landowners and the community is estimated to be in the tens of millions over the project life, with many impacts having permanent, lasting effects.

There are alternatives to tree removal to mitigate risk such as a program to regularly monitor trees affecting the transmission line and removing those that are injured or dead or pose a greater risk. Dominion and its predecessors have used this mitigation practice successfully for 55+ years.  Dominion and its predecessors have lived with the current easement and tree lines and its risks for 55+ years. There is no apparent rationale that supports a major change in risk to justify the immense impacts of the tree removal project.

In the light of analysis, there is no reasonable argument that the risk cost to the transmission line outweighs the impact on landowners, local ecosystems, and the environment. To say otherwise contradicts science, safety engineering and data, and Dominion’s and its predecessor’s risk mitigation practices over the past 55+ years.

We urge landowners and concerned citizens to urge Dominion to reconsider the tree removal plan and publicly discuss the environmental impacts. We further believe that independent landowners should not be treated differently than the US Army Corps of Engineers who are stewards of land affected by the project.

It is not too late to urge Dominion to reconsider the damage to landowners, our community, and environment; and adopt a more reasonable approach to risk mitigation and stewardship of our planet. If you are an affected landowner or concerned citizen, we encourage you to speak up. Write or call your legislators.

Donald and Joanne Marx are local Halifax County landowners with 50+ years’ experience in engineering, analysis, design and systems safety, and environmental assessment.