Statement of the Killdeer
Mountain Alliance to the North Dakota Public Service Commission Regarding the
Proposed Antelope Valley Station to Neset Transmission Project, Case #:
PU-11-696
September 4, 2013
We are deeply concerned that Basin Electric Power Cooperative is
proposing to construct new transmission lines and a 12-acre substation along
the south face of the Killdeer Mountains. We ask the Public Service Commission
to reject this part of the proposed route for the following reasons:
·
The Killdeer Mountains are
important to all North Dakotans for historic, archaeological, ecological,
cultural, and recreational reasons.
·
The Mountains hold deep historical
and cultural significance for the Mandan, Hidatsa, Arikara, Lakota, Dakota, and
other tribes.
·
In spite of mitigation
efforts, the proposed transmission line and substation would negatively impact
the view and experience of the beautiful Killdeer Mountains, both from the
highways and from higher on the Mountain.
·
The proposed transmission
line and substation would pass within the boundary of the 70,000+-acre Killdeer
Mountain Battlefield area, as identified in the 2010 National Park Service
study* (see attached map). The proposed substation would have been in the core
battlefield area (inner circle on map).
We are pleased this location has now been removed from the proposal, but
the proposed transmission line route remains a concern.
·
Basin Electric’s
archaeological finding of “no significant cultural sites” was apparently based
on State Historic Preservation Office records for the battlefield boundaries, which
were not current at the time. These records are in the process of being updated
now to match the battlefield boundaries identified in the National Park Service
study.*
·
However, the National Park
Service study was published in 2010 with the State Historic Preservation Office
as a respondent on the document. We believe the 2010 date of document
completion precedes Basin Electric’s proposal of their transmission routes, so
that information was available to the Basin Electric archaeologist and on the
Internet.
·
In other words, it appears that the Historic Preservation Office did not
communicate adequately with the Basin Electric archaeology consultant about
this, and vice versa.
·
In addition, the State Historic Preservation Office surely knew that
the Killdeer Battlefield qualified for the National Register of Historic
Places.
·
If either of these pieces of information had
been communicated to Basin Electric in their planning process, today’s
discussion would probably not be happening, because, according to their own
testimony, they said that they avoided every site in this project that was
known to be eligible for the National Register of Historic Places. We ask the Commission to request that Basin Electric submit a
revised route based on the amended information.
·
Another reason to delay this
decision is that funding has recently been approved for a two-year collaborative
study of the Killdeer Mountain Battlefield area. North Dakotans deserve to know
the outcomes of this study before a decision is made about a transmission line
through or near the Killdeer Mountain area.
· Basin Electric now wants approval of a second transmission line to meet the needs of the oil and gas industry, and the second line they are proposing is the alternative they originally presented to the Killdeer Mountain route. Does this mean that their proposal no longer lists the “range of reasonable alternatives” that are required by the National Environmental Policy Act (NEPA)? If it doesn't meet that requirement, they should be required to develop other alternatives.
· In addition, the entire environmental impact statement required by NEPA is still in draft stage. Will it be completed before a final decision is made?
· Related to this, the proposed route is a major threat--through electrocutions and line strikes--to nesting, hunting, dispersing, and migrating golden eagles. According to eagle researcher Dr. Margi Coyle, the portion near the Killdeer Mountains would run adjacent to three golden eagle nesting territories and directly through golden eagle hunting territory.
· Furthermore, we have been told that the Sisseton Wahpeton tribe has not been consulted in the Environmental Impact Statement and has not received a copy of the cultural resource report. We ask that you look into this and ensure that they, as descendants of some of those who fought in the Killdeer Mountain Battle, are consulted.
· Finally, the Killdeer Mountains are included on the recent list of forty special places identified by the Governor and the North Dakota Industrial Commission as having unique historical, cultural, and recreational significance to North Dakotans. Although our focus is on protecting the Killdeer Mountains, we respectfully ask the Public Service Commission to reject any portion of this proposed transmission line that would negatively impact these forty places. We owe this to our children, our grandchildren, and ourselves.
· Basin Electric now wants approval of a second transmission line to meet the needs of the oil and gas industry, and the second line they are proposing is the alternative they originally presented to the Killdeer Mountain route. Does this mean that their proposal no longer lists the “range of reasonable alternatives” that are required by the National Environmental Policy Act (NEPA)? If it doesn't meet that requirement, they should be required to develop other alternatives.
· In addition, the entire environmental impact statement required by NEPA is still in draft stage. Will it be completed before a final decision is made?
· Related to this, the proposed route is a major threat--through electrocutions and line strikes--to nesting, hunting, dispersing, and migrating golden eagles. According to eagle researcher Dr. Margi Coyle, the portion near the Killdeer Mountains would run adjacent to three golden eagle nesting territories and directly through golden eagle hunting territory.
· Furthermore, we have been told that the Sisseton Wahpeton tribe has not been consulted in the Environmental Impact Statement and has not received a copy of the cultural resource report. We ask that you look into this and ensure that they, as descendants of some of those who fought in the Killdeer Mountain Battle, are consulted.
· Finally, the Killdeer Mountains are included on the recent list of forty special places identified by the Governor and the North Dakota Industrial Commission as having unique historical, cultural, and recreational significance to North Dakotans. Although our focus is on protecting the Killdeer Mountains, we respectfully ask the Public Service Commission to reject any portion of this proposed transmission line that would negatively impact these forty places. We owe this to our children, our grandchildren, and ourselves.
You have asked that we make
recommendations for alternatives. We
recommend that it be moved to a location that addresses all of the concerns we
have described today. Thank you.
Sincerely,
Rob Sand (Killdeer) and Lori Jepson (Killdeer)
Coordinators, Killdeer Mountain Alliance
Contact information
Killdeer Mountain Alliance
The Killdeer
Mountain Alliance is a loose alliance of local landowners, Native Americans,
hunters, outdoor enthusiasts, scientists, historians, archaeologists, and
others who love the Killdeer Mountains and agree with the mission statement: "The Killdeer Mountain
Alliance exists to preserve the cultural, spiritual, ecological,
archaeological, and historical integrity of the Killdeer Mountains of western
North Dakota and protect them from industrial development that harms the American
Indian sites, plant and wildlife habitat, ranching, hunting, tourism, scenic
beauty, and recreation for which the Killdeer Mountains are known and
loved."
For more information, see our facebook
site—Killdeer Mountain Alliance. See
also a separate site: The Battle for Killdeer Mountain < http://savekilldeermountain.blogspot.com/>
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