Cumberland Chapter Sierra Club Kentucky

The following are comments prepared By Aloma Dew on behalf of the Cumberland Chapter regarding proposed construction of high voltage power lines through private properties in Butler County. These comments were submitted to Joe Settles, Eastern Kentucky Power Cooperative on January 10, 2006.

January 10, 2006

Mr. Joe Settles
Eastern Kentucky Power Cooperative
4775 Lexington Road
Winchester, KY 40391

Subject: Section 106 Consulting Party Status; proposed high voltage power lines in Butler County

Sent via email

As I told you in an earlier letter, I am unable to attend the meetings today. I assume the topics will be identification of Area(s) Potential Effects(APEs) and the identity of National Register listed and eligible resources.

The Sierra Club requests copies of maps showing APEs and cultural resource reports with a reasonable time (thirty days) to comment on the report.

Sierra Club is concerned about the environmental and historical impact, archeological sites, and preservation of prime farmland and wildlife habitat.

Apparently(according to the Cultural Resource Analysts’ report that you hired) the entire Tichenor farm meets “five of the nine commonly used guidelines for determining the edges of a rural historic landscape—historic legal boundaries, boundary demarcations, natural features, current legal boundaries, and long-standing vegetation. The farm retains ten of the eleven discrete areas addressed by NRB 30”(processes and components).

According to the report: “The line travels through Site 1, bisecting the farm between the Carson-Annis house and the non-historic house. This proposed placement of the line introduces a visual intrusion to the rural historic landscape of the site, introducing non-historic characteristics and interrupting the continuity of the historic scene of the site….With the proposed transmission line crossing Annis Ferry Road as well as existing cropland, and the tree lined Green River, the project will diminish integrity of setting, feeling and association. The introduction of visual , vertical elements into the eligible rural historic landscape will alter the appearance of historic spatial patterns, characteristics that make the site eligible as a rural historic landscape. As a result, the proposed project will have an adverse effect on Site 1. As a result of the adverse effect on the site, consultation between EKPC and KHC is recommended in order to avoid, minimize or mitigate this adverse effect.” Visual impacts of night lighting and night light pollution will have a large negative effect on residents and wildlife. You will, of course, do light-of-sight computer modeling to establish the APE for visual impacts, including night impacts. This impact will be much larger than the direct construction impact and needs to be carefully studied.

We again ask you to choose a route using existing right of way and consider the high value of agriculture, history, and culture—especially ancient peoples, habitat destruction, loss of prime farmland, and loss of future use and income of property.

By building on the proposed route, the Tichenor’s farm and other farms will be cut apart. This results in the loss of a sense of place, valuable riparian zones and lost property value.

The Tichenors for generations have maintained valuable riparian zones to keep the Green River, which forms an oxbow at their property, from cutting through and resulting in loss of prime farmland. Construction of power lines through this area will result in disturbance of the land and make it easier for the river to cut through as the integrity of the land is weakened.

The historic and cultural value of this land is beyond a dollar value. One house is on the National Register of Historic Places and three archeological sites will be severely impacted. They, too, are on the National Register. They have been and continue to be studied for their historic and anthropologic value and they are perhaps the only undisturbed sites of ancient inhabitants in the area.

The Tichenor farm is a link to the past in Butler County. The ferry landing at Carson’s Landing is one of the few intact sites along the Green River from the Steamboat Era. Little is left undisturbed in rural Kentucky, but this farm is a Heritage Farm which indicates a special place which has stayed in one family. It was designated in 1992 when it was 88 years old and is now 102 years old. The loss of that continuity has value beyond dollars.

Under current cultural guidelines, the farm fields and property holdings can be considered legitimately within the boundary, so that could expand the boundary to tens or hundreds of acres. Property ownership does not itself limit a boundary, so an historic farm whose land is still intact, even if owned buy several current landowners, could be a huge agricultural district. This area must be looked at as a whole. As these types of areas become fewer in the state, they must be considered in placement of power lines and other impacts.

The Green River at this site is an important environmental and historic resource. The ecosystem supporting flora and fauna of the Green River will suffer from the impacts of construction. This area supports important wildlife habitat—birds and plant life important to the ecological health of the area, and ultimately, all of us, would be disturbed and displaced. The proposed power lines will present very real danger to migrating birds using this route.

We feel there is adequate cause to not use the proposed route.

Sincerely,

Aloma Williams Dew
Associate Midwest Representative
Sierra Club

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