Via Certified MailRon Curry

Regional Administrator — Region VI

U.S. Environmental Protection Agency

1445 Ross Avenue, Suite 1200

Dallas, Texas 75202

Re: Request for Exception to Bayou Aux Carpes §404(c) Final Determination

Entergy Louisiana LLC.

Dear Mr. Curry:

Entergy Louisiana, L.LC. (“Entergy”) respectfully requests an exception to EPA’s 1985

§404(c) Final Deterniination relating to Bayou Aux Carpes (the “Final Determination”). The

justification for this exception is documented in the attached “Request for Exception to Bayou

Aux Carpes §404(c) Final Determination.”

As you know, EPA’s Final Determination prohibits, with limited exceptions, dredge/fill

activities within the defined geographic boundaries of the Bayou Aux Carpes §404(c) area. The

work covered by Entergy’s attached exception request relates to the routine operation andmaintenance of existing transmission and distribution lines (and related rights-of-way) locatedpartially within the Bayou Aux Carpes §404(c) area. The lines were constructed in the 1960’s

and therefore predate the 1985 Final Determination. Although the presence and impact of the

transmission line right-of-way were considered at the time ofthe 1985 Final Determination and

at the time ofsubsequent §404(c) determinations relating to Bayou Aux Carpes, no exceptions

have been recognized for the operation and maintenance of the line.

Entergy requests an exception that will permit work similar to, but less onerous than, that

allowed by existing exceptions granted for pipeline rights-of-way within Bayou Aux Carpes by

the 1985 Final Determination (for Southern Natural Gas) and the 1992 Modification to Final

Determination (for Shell Pipe Line Corporation). As documented in the attached Request for

Exception, potential wetlands impacts from the proposed operation and maintenance activities

are insignificant. These operation and maintenance activities will not interfere with EPA’sresponsibility under 33 U.S.C. § 1344(c) to prohibit activities which will have an unacceptable

adverse effect on municipal water supplies, shellfish beds, fishery areas, wildlife, or recreational

areas.
Assistant General Counsel — Environmental

KMD/sas

EnclosureCc: Mr. William K. Honker

Ms. Barbara Keeler
of dredge and fill material in an area designated as the Bayou Aux Carpes §404(c) Area

in Jefferson Parish, Louisiana. The Final Determination was modified in 1992 (57 Fed.Reg. 13745, April 17, 1992) and 2009 (74 Fed. Reg. 37219, July 28, 2009) to grant

additional exceptions to the dredge and fill prohibition.

Entergy Louisiana, L.L.C. (Entergy) requests an exception to the Final Determination for

the operation and maintenance of a transmission line and a distribution line that have

been in the Bayou Aux Carpes §404(c) Area since the 1960’s — years prior to the Final

Determination.I. BACKGROUND

Entergy has an existing electrical transmission line (the Barataria to Alliance

Transmission Line) and a distribution line which run through a portion of the Bayou Aux

Carpes §404(c) Area. (See Appendix A.) Entergy is requesting an exception to the

Final Determination that will allow for discharges associated with routine operation and

maintenance of its existing transmission and distribution lines. This exception is similar

to (but less extensive than) past exceptions authorized in the Bayou Aux Carpes

§404(c) Area relating to the Southern National Gas pipeline in the original 1985 §404(c)

Final Determination and to the Shell pipeline in EPA’s 1992 modification of the Final

Determination.

Entergy’s transmission line services residential facilities, commercial facilities, military

facilities, Homeland Security facilities, and strategic oil processing facilities in

Plaquemine Parish. The distribution line formerly provided electricity to the aviation

warning lights on one of its structures. All portions of the distribution line within the

Bayou Aux Carpes §404(c) Area are currently out of service and de-energized.

This transmission line is the sole source of electrical transmission to a large portion of

its service area and is a radial feed to the end users. Entergy is in the process of

obtaining clearance to construct another transmission line to provide an additionalsource of electricity to the area. While the specific route has not been determined, it will

not involve the Bayou Aux Carpes §404(c) Area. Once the new line is in place, both

lines will become part of an electrical grid instead of being a radial feed.

A “radial” network (or feed) and a ‘grid” network are two types of transmission systems.

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a line problem or maintenance activity on a radial feed would cause a loss of

transmission to that part of the radial line that has been disconnected from the sole

power source. A grid network is more reliable than a radial feed for higher load

demands, and is better equipped to accommodate future growth load demands.

II. EXISTING TRANSMISSION AND DISTRIBUTION LINES LOCATED WITHIN

BAYOU AUX CARPES 4O4(C) AREA

The Barataria to Alliance Transmission Line is 74,012 feet in total length of which

11,543 feet are within the Bayou Aux Carpes §404(c) Area. (See Appendix B.) The

transmission line right-of-way is 120 feet wide. There are 15 transmission line

structures (see Appendix C) within the wetlands of Bayou Aux Carpes §404(c) Area as

defined in the Final Determination. In general these structures are mounted on metal

foundations that are driven into the ground and held in place by guy wires and anchors.

The distribution line has 15 wooden single poles and approximately 3,415 feet of line

within the Bayou Aux Carpes §404(c) Area. (See Appendix D.) The distribution line

right-of-way is 10 feet wide. Those portions of the distribution line within the Bayou Aux

Carpes §404(c) Area are currently out-of-service and de-energized.

In preparation for construction of the transmission line, Entergy’s predecessor Louisiana

Power & Light (LP&L) obtained right-of-way agreements from landowners in 1964/1 965,

and obtained a Corps of Engineers (COE) Section 10 Permit in 1966 for the crossing of

the Gulf Intracoastal Waterway (GIWW). LP&L constructed both lines in the late

1960’s.1

The transmission line is expected to last another 50-60 years, based upon an inspection

of a short segment of this line after Hurricane Gustav. The only structure requiring

repair at that time was not within the §404(c) area. Preventative maintenance(described in detail below) of the foundations of structures along the line is necessary.

1 At the time of the Final Determination, LP&L was a subsidiary of Middle South Utilities which becameEntergy Corporation in 1989. Entergy Louisiana, LLC is the corporate successor to LP&L.

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North American Electric Reliability Corporation (NERC) regulations, and/or Entergy

s

internal guidelines and procedures.Entetgy also is vigilant regarding outages caused by storms and unexpected

component failures. Outages require immediate repairs in order to re-establish

electrical transmission to its consumers. To re-establish power, Entergy procedures

require an immediate aerial or ground survey (if possible) of the line to determine: the

cause of the outage; supplies and components needed for repair; equipment needed for

repair; number of repair crews; and access route for equipment. Depending on the type

of repairs required, such equipment includes airboats, marsh masters, and marshbuggies. To the best of Entergy’s knowledge and understanding, no emergency orplanned structural maintenance has occurred within the §404(c) area.There are three types of existing metal structures located along Entergy’s lines in the

Bayou Aux Carpes §404(c) Area. One type is a lattice single metal pole Y structure with

four guy wires and anchors. There are two three-pole lattice metal structures (No. 23 &

30) with multiple guy wires and anchors. The anchors are screw type anchors which do

not require digging or filling for installation. The third structure type is a self-supportinglattice metal structure (No. 31) which has four legs based into large concrete footings

and no guy wires or anchors. (See Appendix F.)

In the process of establishing the Bayou Aux Carpes §404(c) Area, the EPA and other

state and federal natural resource agencies identified the environmental settings,characteristics, functions and values of this area. During this process, several man

made features were identified, but mainly in respect to their positive and/or negative

impacts on hydrological conditions. No direct reference was made to the existence of

the LP&L electrical transmission or distribution lines or their impact on natural

resources, even though onsite field trips, sampling efforts, and photo interpretationsrevealed the presence of the transmission line.

On October 16, 1985, EPA issued its “Final Determination of the U.S. Environmental

Protection Agency’s Assistant Administrator for External Affairs concerning the Bayou

Aux Carpes site in Jefferson Parish, Louisiana pursuant to Section §404(c) of the Clean

Water Act,” which referenced “...a 3500 foot long transmission line right-of-way canal...”

It is not cleat if the Final Determination intended to suggest that the canal is related to

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considered by the EPA at the time of the Final Determination, and has also been a

factor in the evaluation of post-i 985 Final Determination modification requests.

• EPA’s document dated July i 986 entitled “Clean Water Act, Section §404(c)

Evaluation, Bayou Aux Carpes, Louisiana” (in Appendix H.2 entitled “Colored

Infrared Photograph of Bayou Aux Carpes Study Area” dated January 19, 1984)

shows the transmission line and its right-of-way.

• In Appendix C.2 (“State Coordination”) to the same EPA document, a letter dated

July 10, 1985 from Dr. C.G. Groat (Assistant to the Secretary of the Louisiana

Department of Natural Resources) provides maps which show the transmission

line right-of-way as a change in wetland type.

• The report entitled “Description of Data Collection, Methodology, and Photo

Analysis Results of Photointerpretive Study of Bayou Aux Carpes Area” dated

June 1985 categorizes vegetation types and land uses into 18 differentcategories. The transmission line right-of-way is not identified as a land use, butthe line’s tight-of-way vegetation types are accounted for and included with those

outside of the right-of-way.

• In EPA’s presentation at a February ii, 2009 public hearing relating to a

requested modification of the Final Determination, one slide clearly shows the

transmission line right-of-way in an aerial photo that was used to indicate the

location of potential levee gapping and plug removal locations. Two of these

gapping locations are adjacent to or within the right-of-way.

• The transmission line tight-of-way can be easily seen in another aerial photo on

page 1-22 in an EPA report of April 2009,

The short term impact of the existence of this transmission line was the conversion of

forested wetlands and scrub shrub wetland types to herbaceous wetlands. No longterm adverse impacts from the transmission line were noted in any of the studies by

EPA or other regulatory and natural resources agencies and their environmental

subcontractors, as presented in the July 1986 EPA document.

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to Shell Pipe Line Corporation are similar to Entergy

s request. Both of the pipeline

companies have been granted exceptions for discharges associated with routineoperation and maintenance of their pipelines, with the requirement that appropriatepermits must be obtained from the Corps of Engineers for individual maintenanceactivities. Entergy likewise requests an exception for “discharges associated with

routine operation and maintenance” of its transmission line. The exceptions granted forSouthern Natural Gas and Shell pipeline activities are based upon EPA’s determination

that environmental discharges associated with the routine operation and maintenancewould not result in unacceptable adverse effects to the Bayou Aux Carpes §404(c)

Area. Entergy’s activities will be equivalent to or less impaciful than the pipeline

maintenance exceptions already determined to be minimal in terms of wetland impacts.

Entergy notes that this proposed exception involves activities with significantly less

wetland impacts than those authorized by the EPA’s February 28, 1992 exception

granted to the Shell Pipe Line Corporation. (57 Fed. Reg. 13745, April 17, 1992.)

• Like Entergy, Shell owned a man-made structure in the Bayou Aux Carpes

§404(c) Area at the time of the Final Determination.

• Like Entergy, the Final Determination provided no exception for Shell’s operation

and maintenance of its structures.

• Shell sought and was granted an exception that authorized:

o the excavation and relocating of the existing underground pipeline to a

deeper depth; and

o routine operation and maintenance of the relocated pipeline.

• Unlike Shell, Entergy seeks an exception only for the routine operation and

maintenance its existing lines. Entergy does not seek to relocate or otherwise

modify its existing lines.

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either less impact or the total avoidance of impacts to the wetlands. Entergy uses nonintrusive methods to conduct maintenance where possible. However, the appropriate

method depends on the type of maintenance required. Where feasible, Entergy

conducts maintenance operations with only airboats and/or helicopters. Recently,

Entergy conducted maintenance activities on a transmission line in the Jean LafiffeNational Historical Park and Preserve using only helicopters.Entergy is committed to using the least damaging equipment and repair methods where

possible for emergency and planned maintenance activities. However, not all repairs

can be conducted solely via helicopter; some repairs require the use of ground

equipment. Entergy uses a team approach in evaluating required maintenance,

methods and equipment, access routes, environmental concerns, availability of

equipment, least damaging techniques, and alternatives. The team develops a

maintenance plan, obtains necessary permits, and executes that plan. For plannedmaintenance activities, there are often restrictions that limit when repairs can be made

in relation to available equipment. For instance, the use of medium-to-heavy lift

helicopters is limited to times when these helicopters are not on fire control duty in the

western states and when there is a low electrical load demand in this area (during thewinter months).

Further minimizing potential impacts to wetlands from the excepted activities is the fact

that all such operations and maintenance activities will be conducted under the permit

authority of either an individual or programmatic U.S. Army Corps of Engineers’ permit.

1. EQUIPMENT

Various types of equipment are used by Entergy for inspections and maintenance and

structure removal. (See Appendix G.) This equipment can be divided into two basic

types: aerial vehicles and ground vehicles. Ground vehicles are either water borne or

amphibious, based on the nature of the terrain, water depth, soils, and vegetation.

Entergy recognizes that, historicaLly, the use of ground vehicles in marsh and wetland

areas has caused adverse impacts to Louisiana wetlands, and is confident that its useof newer and lighter-weight vehicles will cause no long term and minimal short term

impact. Early generations of marsh buggies were modified Model T cars fitted with wide

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pounds-per-square-inch (PSI) exerted by the vehicle; the type of marsh; the type of soil;

water levels; and the amount of erosion occurring naturally in the marsh. The PSIexerted by marsh buggies has been significantly reduced over the years from a range of

3.5-3.8 PSI down to a range of 1.5-1.8 PSI. This improvement was achieved by design

innovations relating to metal weight/strength ratio and increased track width and length.

The marshes in the Bayou Aux Carpes 404(c) Area are of a type and condition (soilswhich are not eroding) that is conducive to the use of marsh buggies without any

resulting long term impacts. Most long term impacts from marsh buggies result from thereduction of soil elevation to the point that emergent vegetation can no longer grow or

tolerate the increased water depth. The use of newer and lighter weight buggies will

eliminate any long-term adverse impacts and minimize short-term impacts. Entergy

notes that the scientific studies cited in the original 1985 §404(c) Final Determination didnot find any long-term adverse impacts resulting from the original construction of the

Barataria-Atliance transmission line in 1960’s. Entergy’s proposed maintenance

activities will be must less impaciful than the original construction.

2. INSPECTIONS

a. Access

Inspections of electrical transmission lines are typically conducted using a Bell 206

series helicopter. Aerial inspections occur at least three times a year, while nonscheduled inspections occur as needed, such as after an outage. Because aerial

inspections on this line are done at low levels within a restricted military airspace and

over a national park, clearances to conduct the survey are obtained from the National

Park Services (NPS), the Federal Aviation Administration, and the U.S. Navy. With this

type of inspection, there is no contact with the ground and no dredge/fill impact. Accessfor aerial inspection is almost directly over the right-of-way, while ground vehicle accesswould be within the transmission line right-of-way.

Ground inspections are conducted either by airboat or marsh master, which cause only

temporary impacts.

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§404(c) Area, landings are not possible.

Ground inspection operations are restricted to airboats or marsh masters. Both of these

vehicle types have insignificant impacts to vegetation and terrain. Vegetation will be

pushed over but no dredge or fill will occur with an aitboat or marsh master. The marshmaster can, but is not likely to, cause some small pressure ridges to occur if turned

sharply. Formation of ridges can be avoided by making wider turns. These potential

minor impacts easily are addressed by manually removing the ridges by shovel to

return the terrain to its original condition. Therefore, such impacts from an airboat or amarsh master would be temporary.

3. Operations and Maintenance (O&M)

a. Access

O&M equipment includes helicopters, airboats, marsh masters and marsh buggies.

Depending on the nature of the O&M activity and terrain conditions, one or more of

these types vehicles may be required. Ground equipment access would be restricted tothe right-of-way.

b. Work Activity

O&M from a helicopter is possible for certain repairs and is used whenever possible.

An advantage of using helicopters is that permits from the COE or Louisiana

Department of Natural Resource Office of Coastal Management are not required,

because no wetlands impacts will occur. Another advantage is that no compensatory

wetland mitigation is required.

O&M requiring ground vehicles also vary with the type of repair required. Types of

equipment for these repairs include airboats, marsh masters, and marsh buggies. The

repairs may require only the use of airboats and/or marsh masters. A significant portionof repairs to structures involve only the above-ground portion of the structure. Belowground maintenance includes maintenance of foundations to prevent corrosion,

foundation repairs, and cathodic protection maintenance.The hypothetical worst case maintenance/repair scenario would involve the structuralfailure of all structures located within the Bayou Aux Carpes §404(c) Area. The ground

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self-supporting structure at the GIWW would be replaced with a large tubular metal Hframe structure. New caisson foundations would need to be inserted into the ground

with a vibratory hammer.

Four marsh buggy types would be needed. One buggy would be equipped with a

Mantis crane for heavy lifts (structure erection, foundations, and vibratory hammer),

while the deck buggy would carry in the new structures and carry out the old damaged

structures. The crane buggy would be used for medium-to-light lifts (unloading, joiningstructure sections, and loading damaged structures), while the bucket buggy would be

used for crews to work on the components of structures. Helicopters capable of lifting

new structures in and old structures out would be used if available.If necessary, Structure # 31 at the GIWW would be replaced using waterbotne

equipment such as barges and tugs. All of the equipment used for the other structures

would be transported using barges with the appropriate equipment mounted on barge

decks. Removal of the foundations to Structure # 31 would require extensive dredging

and filling, since the foundations are four large concrete blocks that were placed well

into the ground. Removing these concrete foundations would have significant impacts

resulting from dredging and filling operations. The removal of these foundations would

also significantly reduce the stability of ground for the replacement structure. Therefore

Entergy would leave the foundations in place and place the new caisson foundations in

the same immediate area.

Caisson foundations for each structure are installed using a vibratory hammer which

uses hydraulic pressure that causes the soils to allow the movement of the caisson

downward without dredging or filling occurring. By using caissons as foundations, the

structures are self-supporting and do not require guy wires and anchors.

Based on these worst case scenario maintenance activities, wetland impacts would be

temporary. No dredging or filling would occur in the replacement of the structures orfoundations. Dredging and filling activities would occur only under other maintenance

scenarios, as described next.

4. Potential Dredge and Fill Activities

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This final impact from foundation maintenance is both temporary and insignificant

because it will last only for a matter of hours and will involve virtually no ecologicalimpact. It requires the temporary removal and replacement of soil from around the

foundation of the structure. First, the top-most soil containing the vegetation and rootswould be removed and set aside. Then the next lower level of soil would be removed

and set aside separately. This would continue until enough soil was removed to expose

the area to be repaired. Upon on completion of the repairs, the lower level soils wouldfirst be put back in place. Then the top soil (with the vegetation and root mass) would

be placed back into its original position at its original elevation. This process would becompleted within a few hours, after which the site will look as it did prior to the dredging.

And impacted vegetation would continue to grow and survive.

Maintenance of the foundations will require one day per structure, including re

establishing soil contours. Routine maintenance of this transmission line would have

insignificant environmental impact. The maintenance methods to be employed will be

the most practical and feasible for both: (1) environmental considerations; and (2)

reliability of the electrical line. Additionally, environmental impacts wiLl be minor and

temporary because routine maintenance activities on this line will entail a total

maximum discharge of 1.35 cubic yards affecting a total of 0.003 acres for the coatingand cathodic protection maintenance of all structures combined.

Similar to pipeline companies subject to FERC regulations, Entergy is required tomaintain right-of-way vegetation to limits defined under FAC-003-2 of FERC regulations.

In contrast to pipeline maintenance activities, Entergy can allow vegetation growth that

does not exceed certain limits. In general, vegetation management is limited to: canopygrowth into the right-of-way; vertical woody vegetation growth within the right-of-way

that exceeds 8 feet; woody vegetation growth into the right-of-way from outside the

right-of-way exceeding minimum height requirements; and vines growing on structures

or guy wires. Entergy does not use mowing for vegetation control within the 404(c)

Area. Herbaceous vegetation is allowed to grow without control except for vines on

structures and guy wires.

Vegetation management measures for controlling the canopy include hand cutting,

aerial side trimming and ground vehicle side trimming. The aerial side trimmer is a

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Controlling vegetation growth within the right-of-way is done with herbicides and/or hand

cuffing. Herbicide application is done via direct application to individual woody plants,either using an Argo vehicle, a marsh master, or an airboat. No aerial or broad spraying

is conducted. Only EPA approved herbicides (approved for aquatic environments) are

use and they are applied only at recommended rates.

The amount of water in the wetlands determines which vehicle would be used. Woodyvegetation growing into the tight-of-way from outside the right-of-way would be hand cut

(including climbing trees to conduct the cutting), with access provided by an Agro,marsh master, or airboat. Vegetation management outside of the right-of-way is limited

to “risk trees.” Risk trees are those that are determined to meet specific factors (seeAppendix H) to qualify as a hazard to the structure, guy wires, or wires. Risk tree

management would be accomplished by hand cutting, with a marsh master providingaccess. The marsh master would remain in the tight-of-way while the crews walk to the

risk tree from the right-of-way. For alt vegetation control measures, cut vegetation

would be allowed to fall to the ground and decompose.

Vegetation control occurs every two years, based upon Entergy’s experience with its

right-of-ways. Entergy conducted vegetation control within the §404(c) area prior to

becoming aware that its rights-of-ways fall within a §404(c) designation. These actions

occurred approximately every two to three years. Access into and within the area wasachieved via airboat, Argo, or marsh master. Vegetation was hand cut as described

above. Entergy’s vegetation control group has been made aware of the Bayou Aux

Carpes §404(c) restriction and will not conduct vegetation maintenance without proper

clearance. Based upon recent aerial observation, side trimming in the §404(c) area will

be needed during 2014. This work would be carried out by hand cutting as describedabove.

Similar to the pipeline companies with existing exceptions to the Bayou Aux Carpes

§404(c) Area designation, Entergy is regulated by state and federal entities regarding

reliability of its services. These entities include the Louisiana Public ServiceCommission (LPSC), FERC, and NERC. The LPSC has enacted new regulationsrequiring its approval of new lines. Entergy is also required to meet the electricalstandards for transmission lines as established by the National Electric Safety Code

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OPERATION AND MAINTENANCE OF THESE TRANSMISSION AND

DISTRIBUTION LINES.

A. THE TRANSMISSION LINE

Theoretical alternatives to this requested §404(c) exception for maintenance activities

and operation include the following:

1) Abandonment of the Barataria-Alliance line.

2) Abandonment of the Barataria-Alliance line and replacement with a line

outside of the Bayou Aux Catpes §404(c) Area.

3) Abandonment of all or most of that portion of the Barataria-Alliance line

that runs through the Bayou Aux Carpes §404(c) Area, and replacement

of the abandoned portion with new transmission line.

For the reasons explained below, these alternatives are economically and practicably

infeasible; would not enhance environmental conditions in the Bayou Aux Carpes§404(c) Area; and would cause additional unnecessary wetland impacts both within andoutside of the Bayou Aux Carpes §404(c) Area.

1. Abandonment of the transmission line

Even discounting the mandatory requirements of regulatory authorities such as theLPSC, FERC, and NERC, the alternative of not maintaining the existing line is not

feasible. The line is the sole electricity source for:

• Approximately 5,000 homes and businesses;

• Important oil and gas infrastructure (pipelines, collection facilities, pumping

stations); and

• Homeland Security and U.S. Coast Guard facilities in Venice, Louisiana.

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the Barataria-Alliance line would leave a significant portion of Plaquemines Parish

without electrical power.

The Barataria-Alliance line is also the secondary source of electricity for critical Defense

and Homeland Security facilities located in and around the Naval Air Station in Belle

Chasse, Louisiana. Until 2013, Barataria-Alliance was the sole source of electricity for

the Naval Air Station. The station is now serviced from a different Entergy substation,

but the Navy and Homeland Security have required that the Barataria-Altiance line

continue to be available as a back-up contingency.

Existing transmission lines are inadequate to provide for the projected electrical load for

future growth in this area. Additional major facilities (such as an oil terminal facility

envisioned in COE §404 Permit Application MVN-201 3-0550-EQ) are already being

planned and permitted for this area.

Transmission line removal cannot occur until replacement transmission is in place and

energized. However, the timing of removal would influence many additional impacts. If

the removal is to be delayed for any time, additional dead end structures would have to

be built to provide for the removal of the conductor wire from over roads and the GIWVV.

2. Replacement of the existing line

As mentioned above, Entergy is planning an additional transmission line to provide an

additional source of electricity for the area. The new line will not replace the existing

Barataria to Alliance line, as both will be required to meet the projected needs for the

area. While Entergy’s motivation in planning this new line was not to replace the

Barataria to Alliance line, the following information regarding the new line is offered to

demonstrate the challenges that would be faced in replacing the existing line. Theenvironmental, regulatory, and economic challenges and analyses are similar for theconstruction of either a replacement line or a second line. We also note that merely

replacing the existing line would not address the issues posed by the NERC reliability

standards, nor would it address future growth. Accordingly, abandonment of theexisting line would likely require the construction of two new lines to create the grid

system reliability not provided by the existing radial line.

The purpose of the new line is to eliminate non-consequential load loss due to a single

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category of contingency. During a single contingency outage event of the Nine Mile to

Barataria line, the transmission system would be operating under conditions in which a

large area must be supported via a very long radial configuration. Under that

configuration, service to existing electrical loads would have to be interrupted in order to

reduce the load on the remaining transmission system and raise the voltages in the

affected areas to an allowable level.

Construction of the planned Oakville to Alliance transmission line and installation of an

autotransformer at Alliance will provide a new alternate transmission source directly into

the Alliance area substation to mitigate potential overload and voltage violations, and

meet mandatory NERC reliability standards.

The proposed Oakville to Alliance line is not a substitute for the Barataria to Alliance

line. Both lines will be used to continue to support the Alliance area as part of the

Entergy transmission network. Additionally, in the event of outages in other sections of

the grid, the Barataria to Alliance line is needed to continue to provide transmission to

other substations.

3. Abandoning all or most of those portions of the Barataria-Alliance

transmission line currently in the Bayou Aux Carpes §404(c) Area

Entergy has examined the following alternative routes for the Barataria-Alliance

transmission line that would, for the most part, avoid the Bayou Aux Carpes §404(c)Area. Each of these alternatives would involve abandoning sections of transmission

line in the Bayou Aux Carpes §404(c) Area. (See Appendix I.)

• Alternative Ia is a route that runs from Structure No. 14 in a southeastern

direction through a forested area, residential area, and park, and crosses the

GIWW before turning eastward to tie back into the existing line. This route wouldbe about 2.45 miles in length and would require two new structures for crossing

the GIWW, 13 three-pole metal structures, and 12 single pole metal structures.The estimate cost for this alternative would be $7.4 million, not including wetland

mitigation costs. This alternative would result in 17.8 acres of forested wetlandsbeing permanently converted into herbaceous wetlands. A total of about 22

acres of wetlands would be impacted.

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herbaceous wetlands would occur with this alternative. A total of about 23 acres

of wetlands would be impacted.

• Alternative ic is similar to Alternative la except that it does not cross the GIWW,

but uses the existing crossing structures. This alternative would requite four tall

metal structures to cross the area of Bayou Des Families. It would also require

15 three-pole structures and 10 single pole metal structures. Approximately1,527 feet of the total 2.4 miles of this alternative would be within the Bayou Aux

Carpes boundary, requiring additional structures to be installed within the 404(c)

area. This alternative is estimated to cost $7.2 million, not including wetland

mitigation costs. Permanent conversion of 19.3 acres of forested wetlands to

herbaceous wetlands would occur with this alternative. A total of about 20 acres

would be impacted.

• Alternative 2 runs directly from the Barataria Substation southward to cross the

GIWW, then turns eastward to connect with Alternative 1 b. This alternative has a

total of 4.1 miles with two structures for crossing the GIWW, 8 three-pole metal

structures, and 34 single pole metal structures. This alternative is estimated tocost $12.3 million, not including wetland mitigation costs. Permanent conversion

of 35.6 acres of forested wetlands to herbaceous wetlands would occur with thisalternative. A total of about 42 acres of wetlands would be impacted.

These alternatives would not meet the goal of supplying transmission from the Barataria

Substation. Please note that the specific route for a new line has not been selected or

approved. Entergy prefers that the solution avoid wetland impacts as much as possible.

Entergy also notes that building a single line or two lines on the same route from the

starting point of the new line would not increase the reliability of supplying transmission.

Such a system would still be a radial feed (rather than a grid) from a single source.

4. Regulatory, economic, and right-of-way issues relating to alternatives

Failure to operate and maintain the existing line throughout the Bayou Aux Carpes §404

Area (again, a hypothetical worst-case alternative) would cause other impacts that

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• Jefferson Parish would require permits for new construction.• The NPS would requite a Special Use Permit for any activity on park lands.• The Federal Aviation Administration would requite permits for structures at the

Gulf Intracoastal Waterway, due to the location of these structures within militaryrestricted airspace.

Obtaining new right-of-way agreements from landowners would be a major issue.

Entergy’s experience with the expropriation of right-of-ways from landowners is that

court challenges occur at a higher frequency where there are numerous landowners,

and all of the potential replacement routes here involve numerous landowners. Thecourt system must consider the rights of the landowners, the need and justification for

the project, and the need and justification for the route.A replacement route for the existing line would cause wetlands impacts far outweighing

those involved in operating and maintaining the existing line. These impacts include:

1) Short and long term impacts to wetlands from a new route.

2) Short and long term impacts to residential and commercial areas.

3) Short and long term impacts to the Jean Lafitte National Historical Park

and Preserve.

4) Removal of the existing structures and wires within the Bayou Aux

Carpes §404(c) would have significantly more impacts than routinemaintenance since:

a) Structures would have to be taken out in pieces due to equipment

limitations. Multiple trips by equipment would be required to

remove each structure with foundations. This repetitive tracking in

the wetlands would have significant impacts.

b) Removal of structures would require heavier equipment than

maintenance of structures and foundations, thus increasing

16
b) The conductor (wire) over the highways and the GIVVW would

requite removal. In order to accomplish this, dead end structures

would have to be installed on each side of the highways neat

Structures 16 & 17. Dead end structures would also have to be

installed on either side of the GlW’/V, with one in the §404(c) area

near Structure 30. Accordingly, two dead end structures wouldhave to be constructed within the §404(c) area, resulting inadditional wetland impacts. If the dead ends were not constructed,

there would be risk of a domino-like catastrophic failure of multiple

structures within the §404(c) area. Again, this would lead toadditional impacts as identified above in 4.a & b.

6) Entergy’s experience demonstrates that it typically takes three years to

obtain the necessary permits, clearances, right-of-way agreements, andapprovals for a new line. It would take another year for construction.

Entergy would need to maintain and make repairs to the existing line

during the interim.

7) New right-of-way agreements with NPS would be required for each of the

above alternatives. NPS has special provisions that allow it to grant new

right-of-ways for linear electrical projects within their parks. However, theactual granting of the new right-of-way and permit could be problematic.

B. THE DISTRIBUTION LINE

Those portions of the distribution line located within the Bayou Aux Carpes §404(c)

Area have been out-of-service for some time;2 however, an evaluation is ongoing to

determine if the line should be placed back into service to provide electrical power to

aviation warning lights on Structure 31. Entergy has considered the followingalternatives. (See Appendix J.)

2 Entergy notes that the distribution line no longer provides service to the old Foster Creppel homestead

and nearby structures, which are located in a non-wetland portion of the Bayou Aux Carpes §404(c) Area,as that portion of the line has been de-energized.

17
as defined by the 1985 Final Determination for the Bayou Aux Carpes §404(c)

document. Under this alternative, the line would be installed along an existing

cleared right-of-way for an unimproved road, and would require ordinary toad

vehicles.

• Alternative C - Installing a solar panel system on Structure 31 that would supply

the electrical power for the aviation warning lights. No distribution line would be

required under this alternative. Implementation of the alternative would requirenormal road vehicles.

Entergy’s preferred alternative for supplying power to the aviation warning lights is

Alternative C — installing solar power panels.

Under either Alternative B or C, there are three options for removing de-energized

portions of the existing distribution line.

1. Removal of wire, hardware and wooden poles with marsh buggies. Poles would

be cut flush to the ground and loaded onto marsh buggies for transport to a nonwetland site for staging and disposal at an approved landfill.

2. Removal of wire, hardware and wooden poles with marsh masters. Poles would

be cut flush to the ground and towed to a non-wetland site for staging and

disposal at an approved landfill.

3. Removal of wire and hardware with marsh masters, and allowing wooden poles

to deteriorate in place.

Entergy’s preferred method for addressing the removal of de-energized portions of the

distribution line is #1 removal of materials using marsh buggies.V. SUMMARY

Entergy has concluded that environmental impacts associated with the future routine

maintenance of its electrical transmission and distribution lines would not result inunacceptable adverse effects to Bayou Aux Carpes §404(c) Area’s shellfish & fishery

12
either a COE Programmatic General Permit (PGP) or an individual COE §404 permit.

Entergy’s operation and maintenance activities would be subject to the COE’s P.GP for

projects within a coastal zone boundary. The specific and limited activities authorizedby the PGP are not considered by the Corps to result in significant impacts and do not

require an individual permit. The Corps has issued PGPs for all Entergy’s maintenance

projects in wetland areas, such as a recent project (MVN-2013-01303-EQ).3 Dredgeand fill activities not authorized under a PGP will require an individual §404 permit.

Entergy has evaluated the environmental impacts from its transmission line operation

and maintenance activities and found them to be insignificant. In addition, Entergy finds

that maintaining the existing transmission and distribution lines is the most practical and

feasible option for the environment within (and outside of) the Bayou Aux Carpes

§404(c) Area. Entergy believes that future discharges associated with the routinemaintenance of these transmission and distribution lines wilt be tess than those

authorized by the exceptions described in either the 1985 Final Determination for theSouthern Natural Gas Company pipeline or in the 1992 exception for Shell Pipeline.

Therefore Entergy requests an exception to the 1985 Final Determination for the Bayou

Aux Carpes §404(c) Area for discharges associated with routine operation and

maintenance of its transmission and distribution lines, with the requirement that

individual maintenance activities be authorized, when appropriate, by permits and/or

clearances from the NPS (Jean Lafitte National Historical Park and Preserve), the COE,

and the EPA.

Permit MVN-201 3-01303-EQ relates to a project in the Jean Lafitte National Historical Park and

Preserve -- outside of the Bayou Aux Carpes 404 (c) Area boundaries.

19
Entergy. Entergy Transmission Planning Guy wirelines.

https://www.oasis.oatLcom/woa/docsIEES/EESdocs/transmission planning guy

wii.!i.I

EPA. Bayou aux Carpes §404(c). Transmission Point Presentation. EPA PublicHearing February 11, 2009. New Orleans, LA.

http://www.naevrronmentai.gov/nola_pub!ic

Uat&pjojects/usaceLevee/docsorjginaBayouAuxCarpes404clnalDetVo

Ii 3.pdf

EPA. Bayou aux Carpes Site, LA; Amendment to October 16, 1985 Clean Water Act

Section §404(c) Final Determination. 57. Fed. Reg. 13745 April 17, 1992.

http://www.nolaevnironmental.gov/nola public

dataiprojcts/usace_leveeldocsoriginal/BayouAuxCarpes404cFinalDetVo

Ii 3.pdf

EPA. Clean Water Act Section §404(c) Evaluation: Bayou Aux Carpes, Louisiana. July

1986

hffp:J/www. nolaevnironmental.gov/nola public

dataIpp[ects/usace_vee/docsorjginal/BayouAuxpes4Q4cFinalDetVo

Ii 3.pdf

EPA. Description of Data Collection, Methodology and Photo Analysis Results of

Photointerpretive Study of Bayou Aux Carpes Area. June 19, 1985. Environmental

Monitoring Systems Laboratory, Las Vegas, Nevada.

http://www.nolaevnironmental.gov/nola public

_data/projects/usae levee/%çpjiinaUBayouAuxCa[pes404cFjnajDetVo

Ii 3.pdf

EPA. Final Determination of the U.S. Environmental Protection Agency’s Assistant

Administrator for External Affairs Concerning the Bayou Aux Carpes Site in Jefferson

Parish, Louisiana Pursuant the Section §404(c)of the Clean Water Act. 50 Fed. Reg.

47267 (November 5, 1985).

20
Ii 3.pdf

Groat, C.G. Letter to Dick Whfttington. July 10, 1985.

http:/Iwww. noIaevnironmentgovinjpublic

_Lpfpiects/LçQcpjjinal/BayouAuxCarpes404cFinalDetVo

Ii 3.pdf

NERC. Transmission System Planning Performance Requirements. TPL-001-4

htp:llwww.nerccom/layouts/PrintStandard .aspx?standardnurnber=TPL

001 -4&title=Transmissi stem Ranniig Performance_Requirements &

jurisdiction=United States

NERC. Transmission Vegetation Management. FAC-003-2.

httpJ/www.nerc.corn/files/FAC-OO3pdf

USACE. MVN-2012-01248-MB. Estuary Mitigation Bank Jefferson Parish, Louisiana.

httpJ/wwwnvnisacarmyrnHLPortais/56/docs/regutoryipubJicnotices/20 12 01

428 PNaII.pdf

USAGE. MVN-2013-0550-EQ. NOLA Oil Terminal. Jjttpiuiwwvv

0550pn.pdf

USAGE. MVN-201 3-01 482-EOO. Entergy Louisiana, L.L.C. Barataria-AllianceFoundation Survey.USAGE. LTMA 593. Louisiana Transmission & Light Company. Construction of

transmission line across the Gulf Goast lntracoastal Waterway.

21
APPENDIX

A

VICINITY MAP
INew Orleans Vicinity Map

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TRANSMISSION LINE/BAYOU AUX CARPES MAP
jaataha-AIIiance Transmission Line and Bayou Aux Carpes 404(c) Area

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STRUCTURE MAP
[Structure Identification and Location Map I

f Structure

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APPENDIX D

DISTRIBUTION LINE

BAYOU AUX CARPES MAP
EXIS11NG DIS1RIBU11ON UNE WITHIN 404(C) BOUNDARY

Google Earth Pro 

lull
§404 PERMIT

MVN-3013-1842 EQO
Operations Divis

Eastern Evaluation Section

SUBJECT: MVN 2013-1842 EQO

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Entergy Louisiana, LLC

% Fred 0. Dunham

Kourco Environmental Services, Inc.

3131 Cameron Street

Lafayette, Louisiana 70506

Dear Mr. Dunham:

The proposal to access an existing right of way to temporarily excavate and baclcfttt

77 stes for an engineering survey extending from Barataria to Alliance, Louisiana, In

Jefferson and Plaquemines Parishes, as shown on the attached drawings, Is authorized

under Category II of the Programmatic General Permit, provided that all conditions of

the permit are met. The permittee is aware that this approval supersedes the previous

PGP II dated December 18, 2013.

Prior to commencing work on your project, you must obtain approvals from state and

local agencies as required by Law and by terms of this permit. These approvals include,

hut are not limited to, a permit, consistency determination, or determination of “no direct

or significant impact fNDSI) on coastal waters’ from the Louisiana Department of

Natural Resources, Office of Coastal Management and a water quality certification from

the Louisiana Department of Environmental Quality.

The following special conditions are being made a part of this authorization:

1. The permittee Is aware that structures numbered 17-31, as illustrated In figure 3

of 12, extends through EPA’s Bayou Aux Carpes Section 404(c) area,

Excavation and filling activities are prohibited at these locations.

2. Our Real Estate Division has indicated that your project is located in an area over

which the federal government holds real estate interest. No work may be

performed under this permit until a real estate Instrument is issued by our Real

Estate Division. If you requite further information regarding real estate matters,

call (504) 862-1701. The teal estate Instrument will be Initiated by our Real

Estate Division without further action required on your part.

This approval to perform work Is valid for 5 years from the date of thIs letter.

Permittee is aware that this office may reevaluate Its decision on this permit at any

time the cIrcumstances warrant.
—z

/ Chief, Regulatory Branch

Enclosure
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18 29,781936111 -90.096677778 ii 0

19 29.783166667 -90.094561111 0 0

20 29.784413889 -90.092422222 0 0

21 29.785666667 -90.090302778 0 0

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44 29.753802778 .90.055105556 1 4

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Project: ENTERcY NOW ORLEANS, INC.

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Baratarie to AEtancn

FoundUon Survey

Date:

{ Project No: 09117(2013 __J 1397901

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67 29.71342 2222 -90.029988889

68 29.711438889 -90.018750000

69 29.709341667 -90.01741388970 29.797241667 -90.01610000071 29.705247222 -90.014805556

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82 29.688775000 -89.997200000

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Proect: ENTERGY NEW ORLEANS, INC.

Baraloria to ABlonce

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— H-Pile and Tower Structure

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NO DREDGING OR FILLING AT

STRUCTURES 17-31

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itor Line

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TYPicAL VIEW

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fSEE DETAILS IN FIG. 9 AND 70)

— TYPICAL. WORK SPACE

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ProJ6ct: ENTERGY NEW ORLEANS, INC

Daratarla to AtOance

Foundatton Suivcy

Date: I Prajcct No.:

0011412013 13979.01

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shall not be used for any activity that is part of an overall project for which en individual permit is

required.

2, No activity is authorized under this general permit which may adversely affect significant cultural

resources listed or eligible for listing in the National Register of Historic Places until the requirements for

Section 106 of the National Historic Preservation Act are met. Upon discovery of the presence of

previously unknown historic and/or prehistoric cultural resources, all work must cease and the permittee

must notify the State Historic Preservation OffIce and the Corps of Engineers. The authorization is

suspended until it is determined whether or not the activity will have an adverse effect on cultural

resources. The authorization may be reactivated or modified through specific conditions if necessary, if

it is determined that the activity will have no adverse effect on cultural resources, The CEMVN-PGP

authorization will be revoked if It is determined that cultural resources would be adversely affected, and

an indivlduai permit may be necessary.

3. The ChiUmacha Tribe of Louisiana has stated that the project area Is part of the aboriginalChitimacha homelands. if during the course of work at the site, prehistoric and/or historic aborIginal

cultural materials are discovered, the permittee will contact the Chitimacha Tribe of Louisiana at P.O.

Box 661, Charenton, LA 70523, and CEMVN. CEMVN will initiate the required Federal, State, and

Tribal coordination to determine the significance of the cultural materials and the need, if applicable, for

additional cultural resource Investigations.

4. There shall be no unreasonable interference wIth navigation by the existence or use of the activity

authorized herein. The permittee wilt, at his or her expense, install and maintain any safety lights,

signals, and signs prescribed by the United States Coast Guard, through regulations or otherwise, on

authorized facilities or on equipment used in performing work under the authorization.

5. No activity may substantially disrupt the movement of those species of aquatic life Indigenous to the

water body, including those species which normally migrate through the area, unless the activity’s

primary purpose is to block or Impound water.

6. if the proposed activity involves the Installation of aerial transmission lines, submerged cable, or

submerged pipelines across navigable waters of the United States the following is applicable;

The National Ocean Service (NOS) has been notified of this authorization. You must notify

NOS and this office in writing, at least two weeks before you begin work and upon

completion of the activity authorized by this permit.Your notification of completion must

include a drawing which certifies the location and configuration of the completed activity (acertified permit drawing may be used). Notification to NOS will be sent to the following

address: National Ocean Service, Office of Coast Survey, NICS261, 1315 East West

Highway, Sliver Springs, Maryland 20910-3282.

7. For pipelines under an anchorage or a designated fairway In the Gulf of Mexico the following is

applicable: The NOS has been notified of this authorization. You must notify NOS and this office in

writing, at least two weeks before you begin work and upon completion of the activity authorized by this

permit. Within 30 days of completion at the pipeline, ‘as built’ drawings certified by a professionalengineer registered in Louisiana or by a registered surveyor shall be furnished to this office, the

Commander (dpw), Eighth Coast Guard District, Hale Boggs Federal Building, 500 Poydras Street,

Room 1230, New Orleans, Louisiana 70130, and to the Director, National Ocean Service, Office of

Coast Survey, NICS261, 1315 East West Highway, Silver Springs, Maryland 20910-3282. The plans

must include the location, configuration and actual burial depth of the completed pipeline project.
permit approval and drawings should be mailed to the Comma

d

(

p

), 

g

,

Hale Boggs Federal Building, 500 Poydras Street, Room 1230, New Orleans, Louisiana 70130, about 1 month before you plan to start work. Telephone inquiries can be directed to the Eighth Coast Guard

District, Waterways Management at (504) 671 -.107.9. All activities authorized herein shall, If they involve, during their construction or operation, any

discharge of pollutants into waters if the United States, be at all times consistent with applicable water

quality standards, effluent limitations and standards of performance, prohibitions, pretreatment

standards and management practices established pursuant to the Clean Water Act (PL 92-500:86 Stat

816), or pursuant to applicable state and local laws.

10. Substantive changes to the Louisiana Coastal Resources Program may require immediate

suspension and revocation of this permit In accordance with 33 CFR 325.7.

if Irrespective of whether a project meets the other conditions of this permit, the Corps of Engineers

retains dIscretionary authority to require an individual Department of the Army permit when

circumstances of the proposal warrant this requirement.

12, Any Individual authorization granted under this permit may be modifIed, suspended, or revoked in

whole or in part if the Secretary of the Army or his authorized representative determines that there has

been a violation of any of the terms or conditions of this permit or that such action would otherwise be

in the public interest.

13, The Corps of Engineers may suspend, modify, or revoke this general permit If It Is found In the

public interest to do so.

14, Activities proposed for authorization under the PGP must comply with all other necessary federal,

state, andfor local permits, licenses, or approvals. Failure to do so would result in a violation of the terms

and conditions of CEMVN-PGP.

15. The permittee shall permit the District Commander or his authorIzed representative(s) or

designee(s) to make periodic inspections of the project site(s) and disposal site(s) if different from the

project site(s) at any time deemed necesary In order to assure that the activity being performed under

authority of this permit Is In accordance with the terms and conditions prescribed herein.

16. This general permit does not convey any property rights, either in real estate or material, or any

exclusive privileges; and it does not authorize any injury to property or invasion of rights or any

infringement of federal, state, or local laws or regulations nor does it obviate the requirements to obtain

state or local assent required by law for the activity authorized herein.

17. In issuing authorIzations under this permit, the federal government will rely upon information and

data supplied by the applicant. If, subsequent to the issuance of an authorization, such information and

data prove to be false, incomplete, or inaccurate, the authorization may be modified, suspended, or

revoked, in whole or In part.

18. For activities resulting in sewage generation at the project site, such sewage shall be processed

through a municipal sewage treatment system or, in areas where tie-In to a municipal system is not

practical, the on-site sewerage system must be approved by the local parish sanitarian before construction.

19. Any modifIcation, suspension, or revocation of CEMVN-PGP, or any individual authorization

granted under this permit, will not be the basis for any claim for damages against the United States.
and the Louisiana Department of Wildlife and Fisheries, Comments from reviewing agencies will be

considered in determination as to whether modifications to the general permit are needed.

Should the District Commander make a determination not to incorporate a change proposed by a

reviewing agency, after normal negotiations bolween the respective agencies, the District Commander

will explain in writing to the reviewing agency the basis and rationale for his decision,

22. CEMVN retains discretion to review CEMVNPGP, its terms, conditions, and processing

procedures, and decide whether to modify, reissue, or revoke the permit. If CEMVN-PGP is not modified

or reissued within 5 years of its effective date, it automaticaliy expires and becomes null and void.23, The permittee understands and agrees that, if future operations by the United States require the

removal, relocation, or other alteration, of the structure or work herein authorized, or if, in the opinion

of the Secretary of the Army or his authorized representative, said structure or work shall cause

unreasonable obstruction to the free navigation of the navigable waters, the pormHtee will be required,

upon due notice from the Corps of Engineers, to remove, relocate, or alter the structural work or

obstructions caused thereby, without expense to the United States. No claim shati be made against

the United States on account of any such removal or alteration.

24. ‘ou must maintain The activity authorized by this permit in good condition and in conformance

with the terms and conditions of this permit. You are not relieved of this requirement if you abandon

the permitted activity, although you may make a good faith transfer to a third party as described in

Special Condition 26 below. Should you wish to cease to maintain the authorized activity or should

you desire to abandon it without a good faith transfer, you must obtain a modification of this permit from

this ofice, which may require restoration of the area.

25. If you discover any previously unknown historIc or archeological remains while accomplishing the

activity authorized by this permit, you must immediately notify this office of what you have found. We

will initiate the Federal and State coordination required to determine if the remains warrant a recovery

effort or lithe site is eligible for listing In the National Register of Historic Places.

26. if you sell the property associated with this permit, you must provide this office with a copy of the

permit and a letter noting your agreement to transfer the permit to the new owner and the new owner’s

agreement to accept the permit and abide by all conditions of the permit. This letter must be signed by

both parties.

27. it a conditioned water quality certification has been issued for your project, you must comply with

the conditions specified in the certification as special conditions to this permit.

2. Many local governing bodies have Instituted laws and/or ordinances in order to regulate dredge

andlor fill activities in floodplains to assure maintenance of floodwater storage capacity and avoid

disruption of drainage patterns that may affect surrounding properties. Your project invoives dredging

and/or placement of fill; therefore, you must contact the local municipal and/or parish governing body

regarding potential impacts to floodpiains and compliance of your proposed activities with local

floodplain ordinances, regulations or permits.29. in issuing authorizations under this permit, the federal government does not assume any liabiiity for:

damages to the permitted project or uses thereof as a result of other permitted or unpermitted activities or

from natural causes; damages to the permitted project or uses thereof as a result of current or future

activities underlaken by or on behalf of the United States in the public interest; damages to persons,

property, or to other permitted or unpermitted activities or structures caused by the activity authorized by

this permit, and; design or construction deficiencies associated with the permitted work.

ii:’.;;—\. .

Typical structure type for Structures 17-22 and 24-29.

Note that all of the existing structures are of a lattice construction

design. New structures are of tubular design as shown below.
.J.

I

ii. Tubular H-Frame Metal Structures

Type of H-Frame Structure that would replace STR 31
I
APPENDIX

G

EQUIPMENT TYPES
The Hughes 500 is used to conduct certain repairs as illustrated in the photos, while the

Bell 206 is used for aerial inspection of the transmission line and right-of-way. Sinceneither of these aircraft will land in the 404(c) area, their use will cause no impacts to

the area.

Hughes 500

Bell 206
Heavy lift Helicopter S-61 N

Medium to Heavy Lift Helicopter Kmax
15’ 8’

Vegetation types, typical water levels, and the terrain in the Bayou Aux Carpes 404(c)

area are not suited for airboat use, except when high water levels allow operations.When vegetation is tall and dry, it is difficult for airboat travel. Potential airboat impacts

are generally limited to causing vegetation to lay over: however, repetitive trips over the

same path can cause temporary vegetation loss. This is easily avoided by usingmultiple paths and by minimizing the number of passes made. Certain wetland

vegetation made airboat travel difficult. One such species is the bull tongue plant which

is found within the Bayou Aux Carpes 404(c) area.

Entergy continues to look for new types of equipment and strives to improve its use of

equipment in order to reduce or avoid impacts associated with transporting crews to the

work sites. One such improvement is the development of the gas turbine engine

airboat. The prototype of this airboat has demonstrated that problem vegetation (such

as the bull tongue plant) does not limit or restrict it movement. This airboat may lessen

potential impacts from Entergy’s maintenance activities.

Turbine Engine Airboat Small Airboat

Length 35’ 15’

Width
Length

Width

Track Width

Ground Pressure

The Marsh Master and Argo are amphibious track vehicles designed to travel in the

marsh and swamp areas of the gulf coast. Their very low ground pressure results ininsignificant or no impact to the terrain. During straight-line travel, these vehicles will

not impact the 404(c) area except for pushing down vegetation within the right-of-way.

A sharp turn can cause a small ridge of soil to form. If ridges are created, Entergy will

re-establish natural contours; however, the formation of the ridges can be avoided by

making wider turns.

Specifications:

MMI

12’ 1”

7,4”

24”

1PsI

MM2LX

15’lO”

8’O”

28”

1PSI

Ag to

119”

72”

18”

0.67 PSI
If ridges are created, Entergy will re

establish natural contours; however, the formation

of the ridges can be avoided by making wider turns.

There are different types of marsh buggies that Entergy can use in the 404(c) area.They differ based on the type of equipment carried on the buggy. The buggy can be set

up to carry a Mantis Crane, a crane, utility deck, or a bucket with extension boom.

These buggies exert a ground pressure ranging from 1.5 PSI to 1 .8 PSI. The tracks onthese buggies are 5’-6’ wide and the total width the vehicles is 19’-20’.

Mantis Crane Marsh Buggy Crane Marsh Buggy

1

Deck Marsh Buggy
the canopy. Since this equipment does not come in contact with the ground, there will

be no impacts from the use of the equipment.

/
Marsh buggy equipped with side trimmer.

Similar to the other marsh buggies, this buggy exerts a ground pressure of 1.5 PSI to

1.8 PSI..

The telescoping boom can reach up to 80 feet in height.
This type of tug will draft five feet while

the barge will draft two feet.

(Equipped with a mantis crane.)
APPENDIX

H

RISK TREE CRITERIA
Improve electric transmission reliability by reducing the number of defective off right of

way trees from falling near or into transmission lines.

TREE ASSESSMENT METHOD:

Utilizing a professional forester/arborist to visually evaluate and mark all trees along the

right of way edge as well as off the right of way for the presence of structurally defective

or weak tree conditions that have a high likelihood of leading to tree failure. Individual

tree assessments help to determine and indicate which trees exhibit a higher degree ofriskfor failure. Tree inspections consider environmental and physical factors such as

structural defect, root health, tree lean, insect/disease infestation, root wash, plantvitality/vigor, etc.

ASSESSMENT GUIDLINES FOR TREE REMOVAL:

Trees that exhibit one or more of the following characteristics and have sufficient height

to fall within the Minimum Vegetation Flashover Approach Distance (as documented in

Entergy’s TVMP - AM-SV-FAC-OOl) of the conductor are candidates for removal:

1. All trees that have visible rotten wood or a hollow in the trunk.

2. Any tree having a “Cat Face” or stem canker at or below conductor height ofthe line.

3. Any tree measuring a lean of 25 degrees or more from vertical angle leaning toward

the line.

4. Trees having a ground swell or showing soil separation within the root zone opposite

the line side ofthe tree. Such trees possess a high risk for structural plant failure.

5. All trees adjacent to or located in free flowing drains or creeks where any ofthe root

system is exposed.

6. Trees located on hillsides where roots are exposed and where erosion is probable

(critical in Loess Hills, sandy soils and shallow soils).

7. Trees that have their root system severely damaged by digging or shearing ofthe soil.

8. MI pine trees that exhibit a yellowing of the crown or reddish-brown foliage, beetle

excursion /dust maybe present around the base of the tree. Bark slippage or’ void barkareas could also be present.
p

g 

g

away from the line,

11. All tree species having a doub]e forked (co-dominate leader) crown with included

bark, and one fork is facing the line (conductor zone).

12. Trees with pronounced swelling on the trunk or the base of the tree, which exhibits

signs of internal wounds/decay, or other weakness. This is often found on older

hardwood trees, Note: Some hardwood tree species are typical of this characteristic.

A couple of examples would include Black gum (Nyssa sylvatica) a,id Batdcypress

(Taxodlum distuchum).

13.A1l tree species showing evidence of physical damage caused by beavers

andior other animals,

14. All tree species that are not indigenous to saturated soils and are

currently located in standing water, or show evidence of being in standingwater for long periods of time (exhibit crown die back, butt rot andlor root

damage/decay.)

15.Trees left standing along or’ near’ the ROW edge from recent forestry clear’-

cut or thinning operations. Note: Large single trees or’ small clusters oflarger’ trees left standing within a stand of smaller’ trees increase the risk

to wind throw due to the lack of stand support.

CU ME:

To accurately determine tree heights, all tree height measurements shall be taken using

proven and applicable forestry/utility measuring devices (examples may include but are

not limited to Clinometer, Vertex 111 with Transponder, TruPulse Laser/Rangefinder,

etc...).

Trees with any of the listed criteria that have the ability to fall within the applicable

Transmission Minimum Vegetation flashover Approach Distance as documented in

Entergy’s TVMP (AM-SV-FAC-00l) should be marked and recorded as a removalcandidate.

All trees martced for removal shall be marked at 4 1,2 feet (54”) (dbh) from ground linewith florescent tree marking paint. The paint shall be on the trunk face nearest to the line

and a second paint spot on the tree base.
If requested by Entergy Transmission,

Contractor shall determine and record the GPS location for each tree marked. Contractor

shall document data for dispute resolutions and/or insure proper landowner payments.

Contractor shall take, store, maintain and file digital photographs for each tree marked

and reference all data on a per landowner and/or per structure(s) basis.

All timber volume records will be forwarded to the appropriate Right-of-Way Agent

and/or Vegetation Operations Coordinator for processing.

All trees marked for removal using this assessment guide line should have sufficient

height to come within the applicable Transmission Minimum Vegetation flashover

Approach Distance of the nearest electric conductor (documented in Entergy’s TVMP -AM-SV-FAC-OO1).
APPENDIX I

ALTERNATIVE ROUTES FROM THE BARATARIA

ALLIANCE TRANSMISSION LINE MAP
Google Earth Pro

IAfternave Routes For Barataria-Ailiance Transmission Line

mesF -

MIII -t
ALTERNATIVE• ROUTES

DISTRIBUTION LINE
Distribution Line Alternatives

Existing mute &

ole Locations of

tribution Line

Ex

U

- Panels on

pproximate

oundary of Non

wetland Area as

1985

Google Earth Pro -

1 flflfl

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