HRAB 02-15-11 Meeting AgendaMEMORANDUM
TO: Historic Resources Advisory Board
FROM: Candice E. Perkins, AICP, Senior Planner`
RE: February 2011 HRAB Meeting Agenda
DATE: February 7, 2011
COUNTY of FREDERICK
Department of Planning and Development
540/665-5651
FAX: 540/665-6395
The Frederick County Historic Resources Advisory Board (HRAB) will be meeting on Tuesday.
February 15 2011 at 6:30 .m., in the Board of Supervisors Executive Session Room* in the
Frederick County Administration Building, 107 North Kent Street, Winchester, Virginia. The
HRAB will discuss the following items:
AGENDA
1. 2011 HRAB Meeting Dates.
2. Review of Resources Impacted by the Construction of the Trans -Allegheny Interstate
Line (TrAIL).
3. Review of Resources Impacted by the Proposed Location of PATH
Please contact this office if you will not be able to attend the meeting. Thank you.
*PLEASE NOTE MEETING LOCATION
Access to this building is limited during the evening hours. Therefore, it will be necessary to
enter the building through the rear door of the Board Room. I would encourage Committee
members to park in the County parking lot located behind the new addition (accessible off of
Cameron Street).
CEP/bad
Attachments
107 North Kent Street, Suite 202 • Winchester, Virginia 22601-5000
FREDERICK COUNTY
HISTORIC RESOURCES ADVISORY BOARD (HRAB)
2011 TENTATIVE MEETING DATES
January 18, 2011 — cancelled
February 15, 2011
March 15, 2011
April 19, 2011
May 17, 2011
June 21, 2011
July 19, 2011
August 16, 2011
September 20, 2011
October 18, 2011
November 15, 2011
December 20, 2011
HRAB meetings are tentatively scheduled for the third Tuesday of each month and begin at
6: 30p. m. For further information, please call Candice Perkins at 540-665-5651.
Item # 2 - TrAIL Project
Representatives (GAI Consultants) for the Trans -Allegheny Interstate Line (TrAIL) project have
contacted the County to solicit opinions from interested parties regarding potential effective
mitigation measures for historic properties that have been impacted by the construction of the
line. An Assessment of Impact report was submitted by GAI Consultants, Inc. (GAI) to the
Virginia Department of Historic Resources (VDHR) in November 2010. This report documented
and assessed the visual impacts introduced by the TrAIL project to historic properties in
Frederick County. In a letter dated December 22, 2010, the VDHR concurred with GAI's findings
that the three historic properties (Funkhouser House, Little North Mountain Farm, and
Woodbine Farm) described in the attached document required alternative mitigation due to
the visual impacts introduced by the TrAIL project.
Staff is seeking suggestions from the HRAB for potential effective mitigation measures for the
impacted historic properties. Suggestions from the HRAB will be forwarded to GAI Consultants.
Attachments: 1. Information about the impacted properties from GAI.
2. Map from GAI identifying the location of the properties.
Funkhouser House (034-1397)
Cedar Creek Grade
Frederick County
The Funkhouser House is in a state of ruin. The main dwelling dated from circa 1770 and was
constructed of stone. Limited information on the house was gathered during a 1992 survey, but it
originally stood two stories tall, had two
stone chimneys, and a water table.
Currently, only a portion of the northeast
corner of the house and the stone chimney
stacks remain. A stone summer kitchen was
located north of, and immediately adjacent
to, the main dwelling. The kitchen is the
most intact building original to the property,
although it, too, is in ruinous condition.
Portions of all four walls remain and are laid
with coursed rubble stones. A window and
door opening are evident.
Funkhouser House -Main Dwelling and
Kitchen, Facing West
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Outbuildings that were recorded in the previous survey but that are no longer extant include: a spring
house, privy, smoke/meat house, and slave/servant quarters. Remnants of these buildings are still
present, as scattered stones and partial foundations are located on the property, primarily near the main
dwelling.
Funkhouser House -Barn, Facing
Northeast
A posted forebay bank barn is located
northeast of the main dwelling. Built on a
stone foundation, this barn is clad in
1 7 -
weatherboard siding with corner boards.
The side gable roof is covered with standing
seam metal, and the fenestration consists of i t
fixed sash windows. Louvered vents are =-
located throughout the barn, and curved
stone walls line the earth ramp on the west
elevation. A wood frame animal shelter is
located just northwest of the barn. The -
animal shelter features a wood pier
foundation, vertical wood siding, and a cat slide roof clad in standing seam metal and trimmed with
exposed rafter tails. The fagade remains open. A modern pavilion and shed are also located on the
property.
The Funkhouser House has been determined potentially eligible for NRHP listing under Criterion A, as a
contributing resource to the larger Ireson Springs Farm Historic District.
Little North Mountain Farm (034-1073)
Cedar Creek Grade
Frederick County
The Little North Mountain Farm currently consists of a main dwelling, barn, spring house,
vehicle/equipment shed, machine shed, garage, and a poultry house. The main dwelling, constructed
cl810, stands on a continuous stone foundation. Stucco has been applied to the exterior walls, and a
standing seam metal clad gable roof tops the house. Two gable roofed dormers are located at the rear.
combination of 6/6 double -hung wood sash and vinyl sash windows completes the fenestration. A four -
bay porch supported by square columns is located on the fagade. There are two interior end brick
chimneys, as well as a modern concrete
block flue in the east gable end. Appended
to the rear of the dwelling is a one-story, V,
shed roofed enclosed porch with vinyl
casement windows. A stone summer kitchen
has been attached to the northeast corner of
the house. The kitchen features a gable roof
with standing seam metal and an interior end
brick chimney.
Little North Mountain Farm—Main
Dwelling with attached Summer Kitchen,
Facing Northwest
A
The posted forebay bank barn is constructed on a stone and concrete block foundation. The exterior walls
are clad in vertical wood siding, louvered vents are located throughout the barn, and its gable roof is
covered with V -crimp metal. Immediately adjacent to the barn is the machine shed. It stands one story tall
and features board and batten siding, a shed roof with standing seam metal, and two open bays on the
fagade (south elevation). The four -bay garage is clad in board and batten siding and has a shed roof with
3 V -crimp metal.
Little North Mountain Farm—Barn, Facing
East
The spring house's foundation and walls are
constructed with coursed rubble stone, and
stucco has been applied in places. A gable
roof with standing seam metal and exposed
rafter tails tops the building. Located at the
end of the driveway, the vehicle/equipment
shed features a parged masonry foundation
and a gable front roof clad with asphalt
shingles. A combination of vinyl, board and
batten, and vertical wood siding has been
applied to the exterior walls. The poultry
house stands on a stone foundation and has
been re -sided with vinyl. A side gable roof clad with standing seam metal tops the building,
elevation is marked by a vertical wood door with strap hinges and a poured concrete stoop.
The south
The VDHR has determined that the Little North Mountain Farm, as a contributing resource to the Ireson
Springs Farm Historic District, is potentially eligible for NRHP listing under Criterion A.
Woodbine Farm (034-5075)
829 Vaucluse Road
Frederick County
The main house of Woodbine Farm was constructed circa 1880. This frame vernacular dwelling with two-
story rear ell stands on a continuous stone foundation and is covered with aluminum siding. The house is
topped with a side gable roof that is clad in standing seam metal. 2/2 double -hung wood sash windows
comprise the fenestration, and the first floor
windows on the facade feature decorative 1` F
shutters. A modern shed roof porch has been
attached to the facade. The porch is built on
a pier foundation and features turned wood
posts and a wood balustrade. It appears that
a one-story, gable roof outbuilding, possibly , ;'•
a shed, has been appended to the rear of the
dwelling through a one-story, shed roof
addition. _ s
Photograph 23. Woodbine Farm—Main
Dwelling, Facing West
Adjacent to the dwelling stands a wood I
framed shed. This shed is clad in both vertical wood and board and batten siding. The gable front roof is
clad in standing seam metal and is trimmed with exposed rafter tails. 1/1 double -hung vinyl sash windows
comprise the fenestration. Located in a field at the end of a lengthy dirt driveway stand a barn and
vehicle/equipment shed. The heavy timber
frame barn features a continuous stone
foundation, board and batten siding, and a
side gable roof with standing seam metal. A
forebay is located on the southeast I,
elevation, and an earth bank leads to large
sliding wood doors on the northwest
elevation. The vehicle/equipment shed
stands one-story tall with 3 V -crimp metal
siding and a side gable roof clad in standing II
seam metal. A total of eight open bays are
located on the fagade, including a shed
roofed addition on the northeast elevation.
Photograph 24. Woodbine Farm—Barn,
Facing Northeast
With its current assemblage of agricultural outbuildings and its surrounding orchards, pastures, and pond,
Woodbine Farm conveys the sense of a historical farmstead and stands out as an example of an
agriculture -related property in Frederick County. Although the main house has lost integrity through
additions and alterations, the associated outbuildings are well preserved and retain sufficient integrity to
convey their architectural significance, particularly the barn. As such, the Woodbine Farm has been
determined potentially eligible for listing on the NRHP under Criteria A and C by the VDHR.
UNKHOUSER HOUSE
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Item # 3 - PATH Proposed Location
As evident by Item #2 (TrAIL), the construction of new electrical facilities in Frederick County
has the potential to impact historic properties. While TrAIL has already been constructed and
the visual impacts to historic resources have been identified, Frederick County has another
electrical facility currently under review by the SCC that could impact additional historic
properties. The PATH Allegheny Power Transmission Corporation is currently proposing a 765
kV Transmission Line through Frederick County (see Attachment 1— MAP).
As evident by the Attachment, PATH could impact a large number of historic properties.
Frederick County has identified 86 historic properties within 1.5 miles of the proposed PATH
facility. The Virginia Department of Historic Resources (DHR) commented on the PATH
application in November of 2010. DHR commented on 13 properties (listed and eligible) that
could have visual impacts (See Attachment 3).
Due to the impacts currently experienced by TrAIL, Frederick County should evaluate the
potential impacts on identified historic properties that could be seen from the construction of
PATH and offer suggestions for mitigation prior to the facility receiving approval from the SCC,
as well as recommend that PATH thoroughly evaluate the historical resources that may be
affected.
Staff is seeking suggestions from the HRAB for potential effective mitigation measures for the
impacted historic properties. Suggestions from the HRAB will be forwarded to the County
Attorney.
Attachments: 1. MAP —PATH Location
2. List of Properties within 1.5 miles of the proposed PATH location
3. Letter from DHR
4. Additional information from the PATH Environmental Summary Report
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Frederick County, Virginia
Historic Landmark Study
Properties within 1.5 miles of Proposed PA`rH Route
ID Property Description VLR NRNP MilesDist
34-156
Saspirilla Springs
0.606
34-731
Woodside
0.202
34-157
Crumly-Lynn-Lodge
6/8/2006 9/6/2006
0.042
House (Northwood)
34-926
Branson, Nathaniel House
0.073
34-929
Lupton, Hugh House
0.108
34-928
Lupton -Hodson House
0.15
34-934
Cather Apple Packing Shed
0.264
34-935
Clearbrook Feed & Supply
0.35
34-936
Dick, L.O. House
0.42
34-708
Clearbrook Presbyterian
0,328
Church
34-730
Mt. Prospect
0.009
34-1198
Owens House
0.046
34-711
Blue Ball Inn
0.984
34-685
Brucetown Methodist
0.888
Church
34-680
McClure House
0.889
34-114
Zinn House
1.026
34-717
Rose Lawn
1.069
34-113
Kenilworth
1.288
34-1167
Morrison -Berg House
1.104
34-486
Sunrise
10/19/1994 2/8/1995
0.728
34-161
Willa Cather Birthplace
9/21/1976 11/16/1978
0.598
34-162
Willow Shade
12/12/1989 12/18/1990
0.632
34-23
Old Stone Church
12/6/2000 7/5/2001
0.905
34-151
Green Springs Grocery
0.864
34-1050
McKown-Russell House
0.219
34-1047
E.B. Clevenger House
0.02
34-103
Springdale
1.499
34-1092
Clayton House
1.046
34-677
Cochran House
0.294
34-6
Hopewell Friends
11/15/1977 3/28/1980
0.682
Meetinghouse
,
ID
Property Description VLR NRNP
MilesDist
34-1482 Poplar Hill
1.262
34-1457 Cochran, Dr. H.W. House
1.255
34-136
Waverly
0.849
34-154
Locust Level
1.142
34-155
Pitzer House
0.213
34-966
Ridgeway House
1.24
34-1056
Glebe, The
0.741
34-1465
Crim, Hugh House
0.273
34-485
Griffin, John House
0.701
34-1516
White -McKee House
1.059
34-480
Smith, Dr. S.J. House
0.595
34-500
Madis House
0.66
34-502
Old Gainesboro School
0.117
34-513
Log Complex, Rt. 684
0.384
34-895
Ebenezer Christian Church
1.21
34-897
Ulmer, A.K. House
0.839
34-904
Anderson, Rual P. House
1.156
34-1094
Smith, Jeremiah House
0.842
34-1514
Smith -Fries House
0.136
34-1525
Never Rest Farm
0.233
34-18
Cather-Glaize-French
1.184
House
34-48
Springfields
0.732
34-104
Barrett House
0.56
34-150
Bailey -Fries House
0.574
34-149
Barrett -Fries House
0.674
34-258
Ridge School
0.311
34-612
Staub, L.H. House
1.425
34-615
Pine's Store
1.122
34-625
Stimmel-Milburn House
1.502
34-639
Foxtrap Farm
1.124
34-643
House, Rt. 739
0.292
34-645
Reese House (barn)
0.091
34-648
Shady Knoll Farm
0.132
34-652
White Hall Grocery
0.386
34-657
White Hall Methodist
0.5
Church
ID
Property Description VLR NRNP
MilesDist
34-659
White Hall School
0.617
34-663
Brown House
0.41
34-664
Smoke's Dr. House
0.404
34-667
Conrad, H.F. House
0.636
34-669
Cook, C.R. House
0.478
34-673
Griffith -Ritter House
0.478
34-674
Welltown School
0.478
34-676
Wright -Teets House
0.602
34-1471
Clevenger -Russell House
0.066
34-1472
Russell Tenant House
0.123
34-1474
Snow Hill
0.106
34-1475
Forty Oaks
0.032
34-1486
Robinson -Miller House
1.048
34-1487
Barrett -Daly House
0.362
34-1488
Bennett -Daly House
0.148
34-1479
Cedar Hill Community
0.176
34-630
Gainesboro School
0.654
34-345
Jobe House & Woolen Mill
0.718
34-401
Anderson's Tavern
0.265
34-1519
Lockhart -Morrison House
1.151
34-137
Branson House
0.047
34-153
Dillon -Boyles House
0.68
3
Douglas W. Domcnech
Secretary of Natural Resources
November 4, 2010
FA
d
W
a
a COMMOra W EAI.' H of VIRGINIA W
Department of Historic Resources Kathleen S. Kilpatrick
2801 Kensington Avenue, Richmond, Virginia 23221 Director
Tel: (804) 367-2323
Fax: (804) 367-2391
TDD: (804) 367-2386
www.dhr.virginia.gov
Ms. Julia H. Wellman
Department of Environmental Quality
Office of Environmental Impact Review
629 East Main Street, Sixth Floor
Richmond, VA 23219
RE: PATH 765 kV Transmission Line — PATH Allegheny Virginia Transmission Corporation
SCC #PUE-2010-00115; DEQ #10-146S; DHR File No. 2008-0945
Dear Ms. Wellman,
We have received the application to the State Corporation Commission (SCC) for the project
referenced above. We have also received the document entitled Pre Application Analysis, Welton
Spring -Kemptown PATH 765 kV Transmission Line, Frederick, Clarke, and Loudoun Counties,
Virginia (September 2010; "Pre -Application Analysis") prepared for PATH Allegheny Virginia
Transmission Corporation by The Louis Berger Group, Inc. and Burns & McDonnell in accordance
with DHR's Guidelines for Assessing Impacts of Proposed Electric Transmission Lines and Associated
Facilities on Historic Resource in the Commonwealth of Virginia (2008; "Guidance"). It is unclear
whether the Pre -Application Analysis was submitted to the SCC as part of the application; however,
we recommend that it be entered as .part of the case so that it may be fully considered by the
Commission.
The comments below are intended as technical assistance to the SCC and Allegheny Power regarding
the potential impacts of this project on known historic resources and supersede DHR's July 24, 2009
comments on PUE-2009-00043 and the earlier analysis dated May 2009. At this time, we have not
been notified by any Federal agency of their involvement in this project or of the applicability of
Section 106 of the National Historic Preservation Act. We reserve the right to provide additional
comment pursuant to Section 106 process, if applicable.
The "Virginia Supplement to the Line Route Evaluation Report" provided in Exhibit 5B of the SCC
application presents numerous large-scale alternatives, including several that require little to no
construction in Virginia. The compiled data for all affected jurisdictions suggest that fewer historic
Administrative Services Capital Region Office Tidewater Region Office
10 Courthouse Ave. 2801 Kensington Office 14415 Old Courthouse Way
Petersburg, VA 23803 Richmond. VA 23221 2"d Floor
Tel: (804) 862-6416 Tel: (804) 367-2323 Newport News, VA 23608
Fnx:(804)862-6196 Fax: (904) 367-2391 Tel: (757) 886-2807
Fax: (757)886-2808
Roanoke Region Office
1030 Pemmr Avenue, SE
Roanoke. VA 24013
Tel: (540) 857-7585
Fax: (540) 857-7588
Northern Region
Preservation Office
P.O. Box 519
Stephens City, VA 22655
Tel: (540) 868-7029
Fax: (540) 868-7033
Page 2
November 4, 2010
SCC PUE-2010-00115; DHR File No. 2008-0945
properties may be impacted by the proposed route when compared to the other alternatives; however,
the severity of that potential impact is only evaluated for the proposed route and not each of the
composite routes. While certain alternatives may avoid or significantly reduce impacts to historic
properties located in Virginia, the most appropriate alternative should minimize the total impact of the
project across all affected jurisdictions. Our recommendations on the potential effect of the project
pertain only to the proposed route and its minor alternatives evaluated in the Pre -Application Analysis.
According to the Executive Summary in the Pre -Application Analysis, the proposed route for the
PATH Transmission Line extends approximately 176 miles from just outside Charleston, West
Virginia, at the John Amos Power Plant, to a proposed substation at Welton Spring, north of
Moorefield, West Virginia. From this point, the line extends about 100 miles to its ending point at
Kemptown, located east of Frederick, Maryland. Extending east of the proposed Welton Springs
substation, approximately 20 miles of segment two runs through Frederick County, Virginia,
approximately 2,000 feet runs through Clarke County, Virginia, and approximately 10 miles runs
through Loudoun County, Virginia. Three minor alternative routes were evaluated for the sections
crossing Frederick and Clark counties: Alternative Route G, Alternative Route H (proposed), and
Alternative Route I. Exhibit 5C to the SCC application shows that the alignment of Alternative Route
H (proposed) has changed slightly since our review of the previous analysis and the current analysis
considers this amendment. For the section in Loudoun County, two minor alternative routes were
evaluated: Alternative Route L (proposed), and Alternative Route M.
In accordance with DHR's Guidance, the Pre -Application Analysis considered the potential impact of
both the proposed and minor alternative routes on recorded archaeological sites and on known historic
properties listed in the National Register of Historic Places (NRNP) and Virginia Landmarks Register
(VLR) or previously determined eligible for listing located within a one -mile study area. Neither the
Pre -Application Analysis nor these comments considers unrecorded or unevaluated historic resources
in the study area. Further, DHR notes that' the photographic documentation used for the photo
simulation views does not necessarily represent a complete depiction of the visual impacts this project
may have on historic properties.
As listed in the table below, DHR offers comments on the potential visual impacts presented in the
Pre -Application Analysis of Routes G, H, I, and M on listed and eligible properties located within the
one -mile study area. DHR's comments on potential impacts are provided according to the following
levels of impact:
Minimal — Occur within viewsheds that have existing transmission lines, locations where there
will only be a minor change in tower height, and/or views that have been partially obstructed
by intervening topography and vegetation.
Moderate — Include viewsheds with expansive views of the transmission line, more dramatic
changes in the line and tower height, and/or an overall increase in the visibility of the route
from the historic properties.
Severe — Result from a dramatic increase in the height of the transmission lines and towers and
the close proximity of the routes to the historic properties.
Administrative Services Capital Region Office Tidewater Region Office
10 Courthouse Ave. 2801 Kensington Office 14413 Old Courthouse Way
Petersburg, VA 23803 Richmond, VA 23221 2°d Floor
Tel: (804) 862-6416 Tel: (804) 367-2323 Newport News, VA 23608
Fax: (804)862.6196 Fax; (804) 367-2391 Tel: (757) 886-2807
Fax; (757) 886-2808
Roanoke Region Office
1030 Penmar Avenue, SE
Roanoke, VA 24013
Tel: (540) 857-7585
Fax: (540) 857-7588
Northern Region
Preservation Office
P.O. Box 519
Stephens City, VA 22655
Tel: (540) 868-7029
Fax: (540) 868-7033
Q
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Page 3
November 4, 2010
SCC PUE-2010-00115; DHR File No. 2008-0945
Dl
Visual Impact
DNR Comments on
Resource
Resource Name
County
Status
Route
Distance
(Pre -Application
pre -Application
No.
Analysis, Sept.
Analysis
2010
034-0486
Robert Muse
Frederick
VOF
G, H,
0.65
Minimal
Minimal
House
Easement;
I
miles
NRHP/VLR-
listed
034-5024
Romney Wagon
Frederick
NRHP/VLR-
G, H,
026
None
Undetermined - view
Road
eligible
I
miles
due north from
resource to
transmission line is
needed
034-0161
Willa Cather
Frederick
NRHP/VLR-
G. H,
0.58
None
Minimal to None
Birthplace/Rachei
listed
I
miles
Boak House
034-0162
Willa Cather
Frederick
NRHP/VLR-
G, H,
0.58
Minimal
Minimal
House
listed
I
miles
44FK0555
Temporary Camp,
Frederick
Unevaluated
G, H,
Within
Minimal
Additional testing
Lithics Workshop
I
ROW
required
034-0104
Benjamin Barrett
Frederick
NRHP/VLR-
G
0.56
Minimal to none
Undetermined - view
House
eligible
miles
due north from
resource to
transmission line is
needed
034-0104
Benjamin Barrett
Frederick
NRHP/VLR-
H & I
0.49
Minimal
Undetermined - view
House
eligible
miles
due north from
resource to
transmission line is
needed
034-0150
Bailey Fries
Frederick
NRHP/VLR-
G
0.5 miles
Not Evaluated
Resource must be
House
eligible
evaluated according to
Guidance
034-1050
McKown-Russell
Frederick
NRHP/VLR-
1
0.2 miles
Severe
Severe;
House
eligible
View to south, from
resource to
transmission line is
needed to fully
visual impact
043-0006
Hopewell Friends
Frederick
NRHP/VLR-
I
0.6 miles
-represent
None
Minimal to None
Mecting House
listed
034-0137
Branson
Frederick
NRHP/VLR-
G
677 feet
Moderate to severe
Moderate to severe
House/Greenwood
eligible
Farm
034-0137
Branson
Frederick
NRHP/VLR-
H
558 feet
Moderate to severe
Moderate to severe
House/Greenwood
eligible
Farm
034-0137
Branson
Frederick
NRHP/VLR-
1
1112 feet
Moderate to severe
Moderate to severe
House/Greenwood
eligible
Farm
255-5001
Lovettsville
Loudoun
NRHP/VLR-
M
0.3 miles
Moderate
Undetermined - view
Historic District
eligible
from point in historic
district closest to
transmission line is
needed
Administrative Services Capital Region Office Tidewater Region Office
10 Courthouse Ave. 2801 Kensington Office 14415 Old Courthouse Way
Petersburg, VA 23803 Richmond, VA 23221 20° Floor
Tel: (804) 862-6416 Tel. (804) 367-2323 Newport News, VA 23608
Fax: (804) 862-6196 Fax: (804) 367-2391 Tel: (757) 886-2807
Fax: (757)886-2808
Roanoke Region Office
1030 Penmar Avenue, SE
Roanoke, VA 24013
Tel: (540) 857-7585
Fax: (540) 857-7588
Northern Region
Preservation Office
P.O. Box 519
Stephens City, VA 22655
Tel: (540) 868-7029
Fax: (540) 868-7033
Page 4
November 4, 2010
SCC PUE-2010-00115; DHR File No. 2008-0945
In Frederick and Clarke counties, DHR recommends following Alternative Route H (proposed route),
and recommends against following the deviations from the existing transmission line corridor
according to Alternative Routes G and I, as these increase the potential for this project to adversely
impact historic properties. In particular, Alternative Route I brings the line in close proximity to the
McKown Russell House and the Hopewell Friends Meeting House. Impacts from Alternative Route
H on the Branson House are still likely to be moderate-to-severe and should be minimized and/or
mitigated.
In Loudoun County, DHR recommends following Alternative Route L (proposed route), and
recommends against deviations from the existing transmission line corridor followed by Alternative
Route M. In particular, Alternative Route M has the potential to adversely impact the Lovettsville
Historic District.
DHR also requests that information provided to the West Virginia Division of Culture and History
concerning the Alternate Route in Jefferson County, West Virginia, that extends south towards Clarke
County, Virginia be provided to DHR for consideration. DHR understands that this is not the proposed
route for this segment of the corridor, and recommends against it, as it may result in visual impacts on
historic properties in Clarke County. DHR also recommends continued coordination with the National
Park Service, in particular about potential impacts on the Appalachian Trail. Further, DHR strongly
recommends continued public outreach, coordination, and consideration of public comment in the
decision making process.
We request that the SCC take into account the above comments and condition any approval of this
project to require archaeological and architectural studies consistent with DHR's Guidance to fully
assess this project's impacts on historic resources. Furthermore, any approval should be so
conditioned as to direct the applicant to work with DHR to avoid, minimize, or mitigate any
unavoidable adverse effects. If you have any questions concerning the comments, please do not
hesitate to contact me at roger. kirchen(�udhr.vir_ ]g'nia.gov.
Sincerely, '
Roger W. Kirchen, Archaeologist
Office of Review and Compliance
C., Mr. Tim Gaul & Mr. Eric Voigt, The Louis Berger Group
Mr. Cyril Welter, Bums & McDonnell
Administrative Services
Capital Region Office
Tidewater Region Office
Roanoke Region Office
Northern Region
10 Courthouse Ave.
2801 Kensington Office
14415 Old Courthouse Way
1030 Penmar Avenue, SE
Preservation Office
Petersburg, VA 23803
Richmond, VA 23121
2nd Floor
Roanoke, VA 24013
P.O. Box 519
Tel: (804) 862-6416
Tel: (804) 367-2323
Newport News, VA 23608
Tel: (540) 857-7585
Stephens City, VA 22655
Fax: (804) 862-66196
Fax: (804) 367-2391
Tel: (757) 886-2807
Fax: (540) 857-7588
Tel: (540) 868-7029
Fax: (757) 886-2808
Fax: (540) 868-7033
F,
Ca
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W
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Joel H. Peck
DEQ # 10-146S
PUE-2010-00115
Page 4
PROJECT DESCRIPTION
The PATH Allegheny Virginia Transmission Corporation (herein after referenced to as PATH)
submitted a SCC application for the construction of a 765 kilovolt (kV) transmission line. This power
line will connect the Amos substation in West Virginia with the proposed Kemptown substation in
Maryland. The proposed route through Frederick, Clarke and Loudoun counties in Virginia is about 31
miles. PATH originally submitted the proposed project to the SCC in 2009 (review coordinated under
DEQ 09-109S); however, it was withdrawn in January 2010. PATH resubmitted the application in
September 2010 with a modification to the proposed route in eastern Frederick County.
PATH is requesting that the SCC approve the proposed route (H) in Frederick and Clarke counties,
the proposed route (L) in Loudoun, and alternative route (M) in Loudoun County in its entirety across
Loudoun County. PATH is seeking approval to construct the transmission line on the centerline of a
200 -foot right-of-way within a corridor that is 1,200 feet wide. Special circumstances may require a
wider or narrower right-of-way width. In some locations, existing transmission lines will be rebuilt to
contain both the existing line and the PATH line. The typical span length is 1,100 feet, and the typical
structure heights may vary from 130 feet to 160 feet. No new substations or other ground facilities are
proposed for the Virginia segments of the PATH project. The application states that the proposed
route in Frederick and Clarke counties will follow an existing transmission corridor for the majority of
its length. In Loudoun County, the proposed route will follow an existing transmission line for its entire
length.
The Line Route Evaluation and Environmental Report (LRE) (Volume II) describes the potential
environmental impacts along the entire route from West Virginia to Maryland. It includes evidence of
public involvement efforts and coordination with state agencies. It also evaluates all of the proposed
alternative routes and recommends the proposed Virginia route through Frederick, Clarke and
Loudoun counties. The DEQ Supplement (Volume III) describes information specific to Virginia's
requirements. Exhibit 5C (Volume III) describes the modified proposed route along a 5.7 -mile
segment in eastern Frederick County.
Additional Review Required
During the 2010 review, PATH provided (email, C. McAfee/J.Wellman, December 3, 2010) DEQ with
new information regarding its request for approval along Alternative Route M in Loudoun County.
PATH will ask the SCC to approve Alternative Route M in its entirety across Loudoun County. This
information contrasts with the application (Volume I, page 10), which requests approval of Alternative
Route M for the Virginia segments between the West Virginia -Virginia state line in western Loudoun
County and a point just east of Route 671. Therefore, DEQ distributed (email, December 3, 2010) this
new information to state and local reviewers who had commented previously. DCR requested shape
files from PATH for its review. The DEQ Waste Division, DCR Division of Planning and Recreational
Resources and Division of Natural Heritage, the Virginia Department of Health, the Virginia
Department of Transportation and Loudoun County responded that their comments remain valid. The
Department of Game and Inland Fisheries, DEQ Office of Wetlands and Water Protection, Virginia
Marine Resources Commission, DCR Division of Soil and Water Conservation, DEQ Air Division,
DCR Office of Land Conservation, Department of Forestry, DHR, Virginia Department of Agriculture
and Consumer Services, Department of Aviation, Virginia Outdoors Foundation and Frederick County
did not respond.
Joel H. Peck
DEQ # 10-146S
PUE-2010-00115
Page 8
SUMMARY OF RECOMMENDATIONS
Based on the information and analysis submitted by reviewing agencies, we have
several recommendations for consideration by the SCC in its deliberations on the
approval and certification of electric transmission facilities. These recommendations are
in addition to requirements of federal, state or local law or regulations listed above. The
rationale for these recommendations is discussed in the remainder of these comments,
specifically in the Environmental Impacts and Mitigation section.
The DEQ prefers PATH's proposed route (route H) through Frederick and Clarke
counties and the proposed route (route L) through Loudoun County (Environmental
Impacts and Mitigation, item 1(c), pages 11-14). The Department of Historic Resources
(DHR) also prefers the proposed route (route H) through Frederick and Clarke counties
and the proposed route (route L) through Loudoun County.
Loudoun County states that it continues to oppose the construction of PATH anywhere
within the county. However, of the two alternatives, overall the proposed route appears
to be the least environmentally and visually disruptive of the alternatives considered by
PATH. Frederick County states that it continues to oppose the PATH project.
A summary of recommendations follows:
• Conduct an on-site delineation of all wetlands and streams within the project area
with verification by the U.S. Army Corps of Engineers (Corps), using accepted
methods and procedures, and follow DEQ's recommendations to avoid and
minimize impacts to wetlands and streams (Environmental Impacts and
Mitigation, item 1(d), pages 12-14).
• Consider DEQ's recommendations, including the disposal of vegetative debris in
lieu of open burning, regarding air quality protection (Environmental Impacts and
Mitigation, item 4(e), page 17).
Conduct an environmental investigation, if not already done, on and near the
property to identify any solid or hazardous waste sites or issues before work can
commence. Reduce solid waste at the source, reuse it and recycle it to the
maximum extent practicable, and follow DEQ's recommendations to manage
waste, as applicable (Environmental Impacts and Mitigation, item 5(d), pages 18-
19).
• Test and dispose of any soil that is suspected of contamination or wastes that
are generated during construction (Environmental Impacts and Mitigation, item
5(d), page 19).
Joel H. Peck
FA
DEQ # 10-146S
a
PUE-2010-00115
FA
Page 9
M]
W
Coordinate with the Department of Conservation and Recreation ) about
(DCR4
s �
conducting and reviewing species surveys and if undocumented karst features W
are discovered (Environmental Impacts and Mitigation, item 6(e), pages 23-24). I-'
• Coordinate with DCR for updates to the Biotics Data System database if a
significant amount of time passes before the project is implemented
(Environmental Impacts and Mitigation, item 6(e), page 24).
• Coordinate with the Department of Game and Inland Fisheries (DGIF) pertaining
to (i) avoidance of stocking and angling activities in Turkey Run and Clearbrook
Run; (ii) habitat assessment for the state -listed threatened loggerhead shrike; (iii)
in -stream work; (iv) recommendations on time -of -year restrictions; (v) wood turtle
protection; and (vi) to ensure the protection of wildlife and other natural
resources; (Environmental Impacts and Mitigation, item 7(d), pages 26-28).
• Coordinate with the DCR and other appropriate parties regarding
recommendations for the protection of recreational resources, including trails,
scenic rivers and scenic byways (Environmental Impacts and Mitigation, item
8(c), pages 29-30).
• Consult and work with the Virginia Outdoors Foundation regarding the protection
of open space (Environmental Impacts and Mitigation, item 9(e), page 31).
• Coordinate with the Department of Forestry concerning its recommendations to
mitigate for adverse impacts on forest resources of the Commonwealth
(Environmental Impacts and Mitigation, item 10(d), pages 32-33).
• Work with the Department of Historic Resources to identify historic resources that
may be affected by the project; avoid, minimize or mitigate any unavoidable
adverse effects; and protect historic and archaeological resources, as applicable
(Environmental Impacts and Mitigation, item 12(d), pages 36-37).
• Coordinate with the Federal Aviation Administration to ensure compliance with
federal aviation regulations (Environmental Impacts and Mitigation, item 15(c),
page 38).
• Coordinate with the Virginia Department of Health (VDH) regarding its
recommendations to protect water supplies in areas where karst topography may
be present and other recommendations, including implementing best
management practices (Environmental impacts and Mitigation, item 16(c), page
40).
• Follow the principles and practices of pollution prevention to the maximum extent
practicable (Environmental Impacts and Mitigation, item 17, page 40).
Joel H. PeCk N
DEQ # 10-146S
PUE-2010-00115 N
Page 10 {�
W
• Limit the use of pesticides and herbicides to the extent practicable �
(Environmental Impacts and Mitigation, item 18, page 401.
W
F�
• Coordinate with Frederick and Loudoun counties regarding local concerns
(Environmental Impacts and Mitigation, item 19, pages 41-48).
Joel H. Peck N
DEG # 10-146S q
PUE-2010-00115
Page 33
W
• Due to the great value of forests and forestland to the Commonwealth, DOF o
recommends a mitigationratin in excess of 1 to 1 more than one acro of land
reforested or protected to every one acre cleared for the power line right-of-way. N
Contact DOF (Todd Groh, Assistant Director, DOF Forest Resource Management
Division, at 434-220-9044 or Todd. Groh@dof.virginia.gov) for additional information.
11. Geologic Resources. The DEQ Supplement (Volume III, page 9) describes the
geology of the areas crossed by the proposed transmission line. Attachment 2.M.1
(DEQ Supplement, Volume Ili) indicates that PATH coordinated with the Department of
Mines, Minerals and Energy (DMME) in 2008 regarding the proposed project. The LRE
(page 3-16) indicates that route H crosses karst topography.
11(a) Agency Jurisdiction. DMME, through its six divisions, regulates the mineral
industry, provides mineral research and offers advice on wise use of resources. The
Department's mission is to enhance the development and conservation of energy and
mineral resources in a safe and environmentally sound manner in order to support a
more productive economy in Virginia.
11(b) Agency Comment. The DMME states that it has no comment on the application.
12. Historic and Archaeological Resources. The DEQ Supplement (Volume III, page
5) states that *16 archaeological, historic, scenic, cultural and/or architectural resources
are within 1 mile of the proposed route in Frederick and Clarke counties. The proposed
and alternative routes in Loudoun County do not have any documented archaeological
sites located within the proposed right-of-way. The north edge of the Lovettsville Historic
district is 0.3 miles from a section of the alternative route in Loudoun County.
12(a) Agency Jurisdiction. DHR conducts reviews of projects to determine their effect
on historic structures or cultural resources under its jurisdiction. DHR, as the designated
State's Historic Preservation Office, ensures that federal actions comply with Section
106 of the National Historic Preservation Act of 1962 (NHPA), as amended, and its
:implementing regulation at 36 CFR Part 800. The NHPA requires federal agencies to
consider the effects of federal projects on properties that are listed or eligible for listing
on the National Register of Historic Places. Section 106 also applies if there are any
federal involvements, such as licenses, permits, approvals or funding. DHR also
provides comments to DEQ through the state environmental impact report review
process.
12(b) Agency Comments. DHR has received the SCC application and the document
entitled Pre -Application Analysis, Welton Springs -Kemptown PATH 765 kV
Transmission Line, Frederick, Clarke, and Loudoun Counties, Virginia (September
2010; Pre -Application Analysis) prepared for PATH by The Louis Berger Group, Inc.
and Burns and McDonnell in accordance with DHR's Guidelines for Assessing Impacts
of Proposed Electric Transmission Lines and Associated Facilities on Historic
Joel H. Peck
DEQ # 10-146S
fl
PUE-2010-00115
p.a
Page 34
W
Resources in the Commonwealth of Virginia (2008; guidance). DHR states that it is
v
unclear whether the Pre -Application Analysis was submitted to the SCC as part of the
OM
application.
W
N
The comments below are intended as technical assistance to the SCC and PATH
regarding the potential impacts of this project on known historic resources and
supersede DHR's July 24, 2009, comments on PUE-2009-00043 and the earlier
analysis dated May 2009. At this time, DHR has not been notified by any federal agency
of their involvement in this project or of the applicability of Section 106 of the National
Historic Preservation Act. DHR reserves the right to provide additional comment
pursuant to Section 106 process, if applicable.
The Virginia Supplement to the Line Route Evaluation Report provided in Exhibit 58 of
the SCC application presents numerous large-scale alternatives, including several that
require little to no construction in Virginia. The compiled data for all affected jurisdictions
suggest that fewer historic properties may be impacted by the proposed route when
compared to the other alternatives; however, the severity of that potential impact is only
evaluated for the proposed route and not each of the composite routes. While certain
alternatives may avoid or significantly reduce impacts to historic properties located in
Virginia, the most appropriate alternative should minimize the total impact of the project
across all affected jurisdictions.
According to the executive summary in the Pre -Application Analysis, the proposed route
for the PATH transmission line extends approximately 176 miles from just outside
Charleston, West Virginia, at the John Amos Power Plant, to a proposed substation at
Welton Spring, north of Moorefield, West Virginia. From this point, the line extends
about 100 miles to its ending point at Kemptown, located east of Frederick, Maryland.
Extending east of the proposed Welton Springs substation, approximately 20 miles of
segment two runs through Frederick County, Virginia, approximately 2,000 feet runs
through Clarke County, Virginia, and approximately 10 miles runs through Loudoun
County, Virginia. Three minor alternative routes were evaluated for the sections
crossing Frederick and Clark counties: Alternative Route G, Alternative Route H
(proposed), and Alternative Route 1. Exhibit 5C to the SCC application shows that the
alignment of Alternative Route H (proposed) has changed slightly since DHR's review of
the previous analysis and the current analysis considers this amendment. For the
section in Loudoun County, two minor alternative routes were evaluated: alternative
route L (proposed) and alternative route M.
In accordance with DHR's guidance, the Pre -Application Analysis considered the
potential impact of both the proposed and minor alternative routes on recorded
archaeological sites and on known historic properties listed in the National Register of
Historic Places (NRNP) and Virginia Landmarks Register (VLR) or previously
determined eligible for listing located within a one -mile study area. Neither the Pre -
Application Analysis nor these comments considers unrecorded or unevaluated historic
resources in the study area. Further, DHR notes that the photographic documentation
Joel H. Peck
DEO # 10-1466
PUE-2010-00115
Page 35
used for the photo simulation views does not necessarily represent a complete depiction
of the visual impacts this project may have on historic properties.
12(c) Agency Findings.
As listed in the table below, DHR offers comments on the potential visual impacts
presented in the pre -application analysis of routes G, H, I and M on listed and eligible
properties located within the 1 -mile study area. DHR's comments on potential impacts
are provided according to the following levels of impact:
• Minimal — Occur within viewsheds that have existing transmission lines, locations
where there will only be a minor change in tower height, and/or views that have
been partially obstructed by intervening topography and vegetation.
• Moderate — Include viewsheds with expansive views of the transmission line, more
dramatic changes in the line and tower height, and/or an overall increase in the
visibility of the route from the historic properties.
• Severe — Result from a dramatic increase in the height of the transmission lines
and towers and the close proximity of the routes to the historic properties.
Visual
OHR Impact
f)HR Comments
CountyResource Resource Name Distance
Applicatio
Analysis,
Application
Analysis
Sept.n 1 1
VOF
034-0486
Robert Muse
Frederick
Easement;
G, H,
0.65
Minimal
Minimal
House
NRHPNLR-
I
miles
listed
Undetermined -
034-5024
Romney Wagon
Frederick
NRHPNLR-
G, H,
0.26
None
view due north
from resource to
Road
eligible
I
miles
transmission line
is needed
Willa Cather
034-0161
Birthplace/Bache
Frederick
NRHPNLR-
G, H.
0.58
None
Minimal to None
I Beak House
listed
I
miles
034-0162
Willa Cather
Frederick
NRHPNLR-
G, H,
0.58
Minimal
Minimal
House
listed
I
miles
44FK0555
Temporary
Camp, Lithics
Frederick
Unevaluate
G, H,
Within
Minimal
Additional testing
Workshop
d
I
ROW
required
Undetermined -
034-0104
Benjamin Barrett
Frederick
NRHPNLR-
G
0.56
Minimal to
view due north
from resource to
House
eligible
miles
none
transmission line
is needed
D
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W
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0
W
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Joel H. Peck
DEQ # 10.146S
PUE-2010-00115
Page 36
12(d) Agency Recommendations. DHR states that its recommendations on the
potential effect of the project pertain only to the proposed route and its minor
alternatives evaluated in the Pre -Application Analysis. DHR has the following
recommendations:
• Enter the Pre -Application Analysis to the SCC as part of the case so that it may
be fully considered.
In Frederick and Clarke counties, follow the proposed route, alternative route H,
and do not follow the deviations from the existing transmission line corridor
according to alternative routes G and I, as these increase the potential for this
project to adversely impact historic properties. In particular, Alternative Route l
brings the line in close proximity to the McKown Russell House and the Hopewell
Friends Meeting House. Impacts from alternative route H on the Branson House
is still likely to be moderate to severe and should be minimized and/or mitigated.
• In Loudoun County, follow the proposed route, alternative route L, and do not
deviate from the existing transmission line corridor followed by alternative route
F�
O
F*
fr.!
W
Q
Q
W
fA
Undetermined -
034-0104
Benjamin Barrett
House
Frederick
NRHPNLR-
H & I
0.49
Minimal
view due north
from resource to
eligible
miles
transmission line
is needed
Resource must
034-0150
Bailey Fries
Frederick
NRHPNLR-
G
0.5 miles
Not
be evaluated
House
eligible
Evaluated
according to
Guidance
Severe;
View to south,
034-1050
McKown-Russell
Frederick
NRHPNLR-
1
0.2 miles
Severe
from resource to
transmission line
House
eligible
is needed to fully
represent visual
impact
043-0006
Hopewell Friends
Meetin House
Frederick
NRHPNLR-
listed
1
0.6 miles
None
Minimal to None
034-0137
Branson
House/Greenwo
Frederick
NRHPNLR-
G
677 feet
Moderate
Moderate to
od Farm
eligible
to severe
severe
Branson
034-0137
House/Greenwo
Frederick
NRHPNLR-
H
558 feet
Moderate
Moderate to
od Farm
eligible
to severe
severe
034-0137
Branson
House/Greenwo
Frederick
NRHPNLR-
1
1112 feet
Moderate
Moderate to
od Farm
eligible
to severe
severe
Undetermined -
view from point
255-5001
Lovettsville
Historic District
Loudoun
NRHPNLR--
M
0 .3 miles
Moderate
in historic district
eligible
closest to
transmission line
is needed
12(d) Agency Recommendations. DHR states that its recommendations on the
potential effect of the project pertain only to the proposed route and its minor
alternatives evaluated in the Pre -Application Analysis. DHR has the following
recommendations:
• Enter the Pre -Application Analysis to the SCC as part of the case so that it may
be fully considered.
In Frederick and Clarke counties, follow the proposed route, alternative route H,
and do not follow the deviations from the existing transmission line corridor
according to alternative routes G and I, as these increase the potential for this
project to adversely impact historic properties. In particular, Alternative Route l
brings the line in close proximity to the McKown Russell House and the Hopewell
Friends Meeting House. Impacts from alternative route H on the Branson House
is still likely to be moderate to severe and should be minimized and/or mitigated.
• In Loudoun County, follow the proposed route, alternative route L, and do not
deviate from the existing transmission line corridor followed by alternative route
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Joel H. Peck
DEQ # 10-146S
PUE-2010-00115
Page 37
M. In particular, alternative route M has the potential to adversely affect the
Lovettsville Historic District.
Submit information provided to the West Virginia Division of Culture and History
concerning the alternate route in Jefferson County, West Virginia, that extends
south towards Clarke County, Virginia, to DHR (Roger Kirchen at
Roger. Kirchen@dhr.virginia.gov) for consideration. DHR understands that this is
not the proposed route for this segment of the corridor, and recommends against
it, as it may result in visual impacts on historic properties in Clarke County.
• Continue coordination with the NPS (Sarah Bransom with the NPS Appalachian
Trail Park Office at 304-535-4003), in particular about potential impacts on the
Appalachian Trail.
• Continue and heighten public outreach, coordination and consideration of public
comment in the decision making process.
• Condition any approval of this project to require archaeological and architectural
studies consistent with DHR's Guidelines for Assessing Impacts of Proposed
Electric Transmission Lines and Associated Facilities on Historic Resources in
the Commonwealth of Virginia to fully assess this project's impacts on historic
resources.
• Condition any approval of this project to require the applicant to work with DHR
to avoid, minimize or mitigate any unavoidable adverse effects.
12(e) Requirement. If there is any federal involvement, PATH should coordinate the
project or any portion thereof with the responsible federal agency and DHR to ensure
compliance with Section 106 of the National Historic Preservation Act, as amended, and
its implementing regulations at 36 CFR 800.
13. Agricultural Lands. The DEQ Supplement (Volume III, pages 7 and 8) indicates
that agricultural districts and lands will be crossed by the proposed route and the
alternate route.
13(a) Agency Jurisdiction. VDACS promotes the economic growth and development
of Virginia agriculture, provides consumer protection and encourages environmental
stewardship. Accordingly, VDACS reviews development projects proposed in Virginia to
ensure there are no adverse impacts on agricultural lands.
13(b) Agency Comments. VDACS did not respond to DEQ's request for comments on
potential impacts to agricultural lands.
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