W. Va. Code § 24-2-11a (d)(1) provides with regard to proposed electric transmission lines, that

"the commission may approve the application if it shall find and determine that the proposed transmission line:

(1) Will economically, adequately and reliably contribute to meeting the present and anticipated requirements for electric power of the customers served by the applicant or is necessary and desirable for present and anticipated reliability of service for electric power for its service area or region; and

(2) Will result in an acceptable balance between reasonable power needs and reasonable environmental factors."

I have prepared a discovery request that seeks to flush out the environmental costs vs the electricity benefits for this specific proposed line. As currently drafted, the discovery request focuses almost exclusively on carbon dioxide emissions.

Please review the proposed discovery request and forward me your suggestions for additions, deletions, changes. I would appreciate in particular any identifiable environmental costs other than carbon dioxide emissions, i.e., endangered species harm, adverse air or water impacts (and a means of quantifying them) and anything else that can be reduced to numbers.

Thanks.

Bill

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William V. DePaulo, Esq.
179 Summers Street, Suite 232
Charleston, WV 25301-2163
Tel: 304-342-5588
Fax: 304-342-5505
william.depaulo@gmail.com
www.passeggiata.com