Coalition Letter to Dominion Power Executives… “We Stand Firm and United”

(3/9/15 NOTE:  Heritage Hunt leadership requested an addition to the financial impact section below)

On March 1st 2015, The Coalition To Protect Prince William County sent the following letter to Dominion Power Executives: Thomas Farrell, Robert M. Blue, Charles Penn, Travis Cutler and Greg Mathe.

Dear Mr. Farrell, Mr. Blue, Mr. Penn, Mr. Cutler, and Mr. Mathe –

On behalf of the thousands who make up the Coalition to Protect Prince William County, and all of our supporters, we write to you today on a matter of extreme urgency and importance. Dominion Power’s proposed overhead transmission lines through residential, business, and rural communities in western Prince William County threaten our residents’ quality of life and put commerce, homes, health, and habitat at risk. Fortunately, you Dominion have proposed an option – the I-66 hybrid route – which will serve all stakeholders concerned, while minimizing disastrous impact on homes, businesses, natural resources and historic treasures. Unfortunately, your public statements, legislative maneuvering, and lack of community involvement indicate Dominion is not considering this option seriously. The Coalition seeks to engage with you to share facts about what routes are being put forward, to exchange ideas about alternatives, and to avoid a situation in which all stakeholders involved in this process –a very large group, including private citizens, local businesses, and political leaders at many levels – face direct or collateral damage.

First a word about who we are: the Coalition is an open partnership of residents, communities, businesses, and non-profit organizations united to preserve and enhance the quality of life, natural resources, and historical heritage of this part of PWC. This area of suburban communities, commercial enterprises, and education and health institutions – surrounded by a Rural Crescent of agricultural, historical, and natural resources – is home to more than 50,000 residents, dozens of federal, state, and county protected sites, and numerous wildlife species, including some deemed federally protected or endangered. Through our leadership, members, and supporting organizations, we have already engaged with our national and state delegates and senators, county leadership, and other stakeholders, to ensure our voices are heard – and heeded. Speaking frankly, Dominion Power has a great deal of work to do with us, both in listening and in acting.

We believe Dominion and its regulator, the State Corporation Commission (SCC), have in Dominion’s proposed alternative the Interstate 66 “hybrid,” a route that serves the interests of both residents and power consumers, while respecting private property and natural preservation. You will note that the Coalition is not advocating one overhead route versus another. We stand united in not taking a “save yourself” approach, but rather in advocating for a solution that serves all residents. We also want to see that the I-66 hybrid route takes into consideration the various commercial interests which have made long-term financial investments many years before Amazon was ever slated for a Haymarket data center site.

You may have also noticed our unity during the January town hall meeting, where over 1,200 people impacted by all the proposed routes gathered to voice their concerns about private citizens being asked – and eventually forced – to sacrifice their property, so that another private entity, widely reported to be Amazon.com, can have its choice of site for a data center, whether or not that makes sense.  Dominion Power’s own representatives have acknowledged publicly to the Washington Business Journal that the power need is for one specific end-user.  Many of us have also been surprised to learn that Dominion’s planned upgrades to the Haymarket substation will provide 700% more power than it says Amazon.com needs. We realize this has nothing to do with benefitting residential customers, as the proposed additional capacity could serve the entire residential need of all Prince William County more than three times over.

From a global perspective, Dominion Power and the SCC must be made aware that the areas, under threat of all the proposed overhead transmission line routes, are included in the Consolidated Natural Resources Act of 2008, and in the Journey Through Hallowed Ground National Heritage Area. The purpose of the JTHG is to recognize the national importance of the natural and cultural legacies of the area, and to preserve, support, conserve, and interpret the legacy of the American history created along the National Heritage Area.  Zoning measures have been put in place by Prince William County in line with the 2014 JTHG Management Plan, approved by the Secretary of the Interior. Placing above ground high voltage transmission lines anywhere in the proposed areas will be in direct violation of the language in the 2008 Act (attached), and will damage our ability to maintain critical historic heritage in one of the most historically vital areas of our country.

When Dominion’s crews and contractors conduct route surveys – we have noticed the aircraft and work vehicles assessing multiple alternatives – it is quite easy for them to focus on the narrow task of finding property to seize as right of way.  What they may fail to notice, or choose not to dwell upon, is that every square foot of property they consider seizing already belongs to someone else –it has a purpose and a use already, which comes at a real cost and has real value. These current purposes and uses exhibit themselves in a wonderful array across the different routes.

The New Road Route winds its way through miles of scenic assets, historic districts, and environmental preserves.  Moving south from New Road, the route starts off immediately encountering sites including the Old Carolina Road and the Journey Through Hallowed Ground protected areas dating from the 1700s; then crosses War of 1812, Civil War, and historic registry sites, including battle sites and slave graveyards.  The line then threads its way through Locust Bottom, Evergreen Estate, and Mt. Atlas (all on the National Register of Historic Places), before running over and through historic churches, graveyards and mills –including the Olive Branch Church from the Virginia Slave Inventory, Bull Run Chapel, and Antioch Church which has been active for three centuries.  The line then runs through the front yard of the Winery at La Grange, whose property dates back to the 1700s, and which is the only winery operating in Prince William County today.  With a final flourish, the New Road line heads south through Oakrum Church (also on the Virginia Slave Inventory), and near the Thoroughfare/Carter’s Switch community founded by freed slaves.  And if dishonoring and disturbing the rest of civilians, slaves, and soldiers from the historic past were not enough, this route also slices through “Serve Our Willing Warriors,” a planned retreat for tens of thousands of our nation’s veterans and their families, designed to speed recuperation from seriously debilitating physical and emotional combat wounds.

This 12.2 mile route will also require the seizure of some 177 acres of farm and residential land, and encroaches on many Resource Protection Areas and official PF01C wetlands designated by both the Chesapeake Bay Protection Act and the U.S. Fish and Wildlife Service –including federally protected Bald Eagle habitat.  It would also mean permanent destruction to the “view shed” of other historic areas including the Bull Run Mountain Nature Preserve, Chapman’s Mill (aka. Beverly Mill), parks, cemeteries, and churches – and over one thousand homes with a ground-level view of the proposed line.

While the New Road Route seems especially designed to impair scenic assets, historic districts, and environmental preserves; the Northern Route targets its 6.6 mile run at residential areas.  Two of these – Piedmont and Heritage Hunt (a Senior 55 Plus community) – have in total almost 3500 homes, two signature golf courses, and are adorned by Little Bull Run Creek, a tributary of the Chesapeake Bay.  Other significant neighborhoods include the Parks at Piedmont, Carolina Estates, West Market, and countless other individual properties and businesses.  The impact on the Heritage Hunt golf course is particularly notable as the Northern Route would render two holes on the back nine and one on the front nine useless, creating Virginia’s – and possibly the world’s – first 15-hole golf course.

The Northern Route also puts at risk the Conway Robinson Memorial State Forest, an historic 444 acre property with direct ties to the first battle of Manassas and donated with national preservation in mind.  Conway Robinson is also the only State Forest located within a growing urban environment.  Across this and other routes, environmental risks will accrue to endangered species impacted, from mussels to mammals, bats, and turtles; wetlands earmarked for protection, including Chesapeake Bay Watershed and Little Bull Run Creek; and the Historic Oak Tree on the Virginia State Registry of specimen trees.  Much of this loss is irreplaceable, as miles of old growth hardwoods would be lost with no new growth allowed due to maintenance, and permanent functional loss of equestrian and pedestrian trails.

The Western Route, which is located primarily in Fauquier County, includes numerous significant sites, including Battlefield Baptist Church, Buckland Farms, and Vint Hill Farms.  The adverse impacts to these sites and this region, which is also part of the Journey Through Hallowed Ground, are just as detrimental as those already noted.

The three routes put forward impacting the town of Haymarket (Railroad, Overhead South of I-66, and Overhead North of I-66) impact both residential and commercial parcels within the town, also adversely impacting their value.  These routes will traverse several designated wetlands and a 100 year flood plain, as well as adversely impacting the town’s Planned Interchange Park. Finally, these routes (similar to all other routes) traverse the area of the town that constitutes a portion of the Journey Through Hallowed Ground.

These individual and distinctive characteristics of the communities along the proposed routes cannot be reduced to dollars and cents, but running the numbers brings attention to the magnitude of the loss which Dominion’s actions will create for property owners. Besides property directly seized for right-of-way or easements, Dominion’s proposed lines will impair residential home values by as much as $7 to $10 million on some routes – using conservative models, a limited sample of in-range residences, and Prince William County tax assessed values.  Use of partially- or fully-buried lines can dramatically reduce this impairment to under $100K or eliminate it altogether.  For a point of comparison, on a per mile basis, property value loss can amount to three times Dominion’s published planning estimate for overhead line right-of-way.

The Coalition’s financial team used two models to estimate residential property value loss from the placement of high-voltage overhead distribution lines on or near property, drawing respectively upon an extensive literature search of appraisal guidance, and from a refereed journal article published in The Appraisal Journal in 2013.  Our models found losses ranging from $1M to $10M depending on the route:

Route Residential Count Total Loss Range Per-Home Loss Range
New Road 197 $4.8 – $7.1 million $24,191 – $35,571
Northern 551 $7.2 – $10.3 million $13,061 – $18,676
Railroad 526 $1.6 – $2.7 million $3,052 – $5,166
Western 83 $748K – $1.2 million $9,013 – $14,233
I-66 Hybrid 1.4 mile buried 9 $49 – $94 thousand $5,386 – $10,450

These estimates are very conservative as they include only residences within 500 feet of the Dominion line; exclude businesses, apartments, and condominiums; cap losses at 20%, while individual sources from our literature survey reached 36%; use Prince William County assessed tax values, which undershoot market value and lag market sales and/or construction completion; and we likely missed a few hard-to-spot properties with structures in trees or otherwise obscured; and we did not hand check every property on every route.

Also, it is worth noting that a comprehensive value impact assessment would require individual parcel appraisals, which is not feasible for our limited resources.  Some communities which anchor around specific outdoor features – such as Evergreen, Heritage Hunt, and Piedmont – could see significantly larger losses as use of outdoor space becomes degraded or impossible, destroying both businesses and home value.

(3/9/15 Paragraph added at the request of Heritage Hunt leadership):

The leadership of Heritage Hunt on the Northern Route conducted their own analysis, and concluded that 135 homes within 100 yards of the Dominion line would suffer 30% devaluation, totaling $19M in loss at median 2014 values, with the remaining 1,600 homes losing 20% and totaling $144M. Evergreen Country Club on the New Road Route, while smaller in scale, could see home values drop up to $250,000-$300,000 per lot and $25-$30M total devaluation if similar loss ratios hold.

More information on value loss for homeowners can be found in the Report of the Joint Legislative Audit and Review Commission to the Governor and the General Assembly of Virginia, Evaluation of Underground Electric Transmission Lines in Virginia.

Besides direct losses, other parties with an interest in property values will face challenges.  First and foremost, Prince William County derives revenue from individual taxpayer property ownership.  In the 20169 zip code, some 19,000 residents with 6,500 residential units represent over $3 billion in the County tax base, which will abruptly face devaluation directly or through real estate sales comparables.  Second, lenders holding mortgages or issuing lines of credit will see the value of their collateral drop. Today, the 20169 zip code outperforms the national average, with only 1-in-8 people “underwater” on their mortgages, versus 1-in-6 across the country.  Depressed property values will evaporate equity, increase risk, and hurt those seeking refinances, loans, or lines of credit.  Third, real estate sales will be hit in the tens of millions, directly on proposed routes and over $100 million in the local pipeline, as sales comparables decline and as prospective buyers lose confidence in the durability of the assumption underlying their purchase – assumptions including preservation of outdoor spaces, view shed, historical and environmental features, and the integrity of local zoning and development commitments.

The point about harm to Prince William County goes well beyond pure finances.  The County has long balanced the need for infrastructure growth and economic diversification with the preservation of quality of life and distinctive features through the use of policies and plans.  Dominion’s proposed lines run counter to the county’s 1998 Comprehensive Plan, which for the first time formally established an urban growth boundary, the Rural Crescent.  The Rural Crescent is the most effective tool the county possesses to protect open space.  Subsequent revisions to the Comprehensive Plan include the “Designated Corridors for Electric Transmission Lines of 150 Kilovolts or More” in the Long Range Land Use Chapter, Land Use Policy 3.14.  Dominion’s proposed lines ignore county directives, by traversing numerous sites protected under the High Sensitivity Areas and County Registered Historic Sites inventory, published in March 2009 as part of the 2008 Comprehensive Plan; and also ignore recommendations and findings made in the recent 2014 Prince William County Rural Preservation Study Report.  Running a double 230kv transmission line through the Rural Crescent, where it will serve NO burgeoning development in the Rural Crescent, is in complete contradiction to Prince William County’s long term goals to preserve open space.

We can work together to shape a positive, productive outcome in which the many stakeholders in the process win, rather than suffering direct or collateral damage.  You have put forward the option, the I-66 hybrid route, which accomplishes that objective, and the Coalition stands ready to engage further with you in support of this option.  We respectively request a meeting, between your leadership and our leadership, within the next 10 days – to reaffirm where we stand, and to understand where you are in the process.

We close by speaking straight from the heart – as citizens, residents, voters, Amazon.com shoppers and (via NOVEC) as consumers of Dominion-generated power.  Is this how you, Dominion Power, want to do business in the Commonwealth of Virginia?  Literally taking property and defiling businesses, homes, history and habitat?  We hope not, but we don’t know for sure.  We realize that financially and politically, Prince William County is a long way from Richmond, but we have the ability to make our voices carry.  You have the power to do the right thing and we hope you choose that option.

Sincerely,
Elena Schlossberg
Executive Director
Coalition to Protect PWC
PO Box 382
Haymarket, VA 20168

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