GRAIN BELT EXPRESS CLEAN LINE

Transcription

1 GRAIN BELT EXPRESS CLEAN LINE ROUTE SELECTION STUDY Prepared For Clean Line Energy Partners LLC Prepared By Louis Berger 201

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3 TABLE OF CONTENTS List of Figures... v List of Tables... vi Acronyms and Abbreviations... vii Glossary... ix Executive Summary... xi 1. Introduction Project Overview Overview of the Regulatory Process Project Timeline and Routing Process Overview Project Description Line Characteristics Right-of-Way Characteristics Converter Stations Project Vicinity Routing Process Goal of the Route Selection Study Process Steps and Terminology Routing Team Members Routing Guidelines General Routing Guidelines Technical Guidelines Data Collection GIS Data Sources Digital Aerial Photography Route Reconnaissance Routing Constraints Routing Opportunities Agency and Public Outreach Regulatory Agency Coordination Non-governmental Organizations Community Outreach Activities

4 3.3.1 Roundtables Public Meetings Route Development Study Area Conceptual Route Development in the Study Area Conceptual Routes Northern Portion of the Study Area Conceptual Routes Central Portion of the Study Area Conceptual Routes Southern Portion of the Study Area Comparison of Conceptual Routes in the Study Area Potential Routes Identification of the Mississippi River Crossing Location Development of the Potential Route Network Revisions to the Potential Route Network Converter Station Alternative Route Evaluation Natural Environment Impacts Water Resources Wildlife and Habitat Special Status Species Geology and Soils Natural Environment Summary Built Environment Impacts Developed Land Uses Agricultural Use (Farm and Pasture/Grassland) Aesthetic Resources Cultural Resources Built Environment Summary Engineering and Constructability Impacts Paralleling and Crossing Existing Linear Features Transportation Network Crossings Constructability Considerations Engineering Summary Identification of the Proposed Route Rationale for the Selection of the Proposed Route Summary of Alternative Route Comparison Segment

5 6.2.2 Segment Segment Segment Combined Proposed Route Combined Alternate Route References

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7 List of Figures Figure 1-1. Project Vicinity Map Figure 4-1. Generalized North, Central, and Southern Paths within the Study Area Figure 4-2. Conceptual Route Development in the Northern Portion of the Study Area Figure 4-3. Conceptual Route Development in the Central Portion of the Study Area Figure 4-4. Conceptual Route Development in the Southern Portion of the Study Area Figure 4-5. U.S. Census Residential Density in the Four State Study Area Figure 4-6. Potential Mississippi River Crossings Figure 4-7. South Saverton Mississippi River Crossing Figure 4-8. Illinois Potential Route Network Figure 4-9. Illinois Revised Potential Route Network Figure Illinois Alternative Routes Figure 4-11 Alternative Routes in Segments 1 and Figure Alternative Routes in Segments 3 and Figure 5-1A. Ecoregions and Hydrology in Segments 1 and Figure 5-1B. Ecoregions and Hydrology in Segments 3 and Figure 5-2A. Special Status Species Habitat in Segments 1 and Figure 5-2B. Special Status Species Habitat in Segments 3 and Figure 5-3. Karst Topograpy and Mining Activity Figure 5-4A. Land Use in Segments 1 and Figure 5-4B. Land Use in Segments 3 and Figure 5-5A. Recreational Resources in Segments 1 and Figure 5-5B. Recreational Resources in Segments 3 and Figure 5-6A. Architectural Properties in Segments 1 and Figure 5-6B. Architectural Properties in Segments 3 and Figure 5-7A. Transportation Infrastructure in Segments 1 and Figure 5-7B. Transportation Infrastructure in Segments 3 and Figure 6-1. Proposed Route and Alternate Route

8 List of Tables Table 5-1. Alternative Routes Water Resource Information Table 5-2. Conservation Lands Table 5-3. Wildlife Habitat within Alternative Routes Table 5-4. Federal and State Special Status Species Table 5-5. Impacts to Special Status Species within the Alternative Routes Table 5-6. Alternative Routes Geology and Soils Resources Information Table 5-7. Land Use Based on Land Cover Table 5-8. Counties Crossed by Alternative Routes Table 5-9. Population Trends Table Developed Land Use Inventory Table Communities Located within 2 miles of Alternative Routes in Segment Table Communities Located within 2 miles of Alternative Routes in Segment Table Communities Located within 2 miles of Alternative Routes in Segment Table Communities Located within 2 miles of Alternative Routes in Segment Table Visually Sensitive Features Table Cultural Resources Table Engineering and Constructability Table Transmission and Pipeline Crossings for Alternative Routes Table Transportation Infrastructure Crossed by Alternative Routes Table Public and Private Airports in Segment Table Public and Private Airports in Segment

9 Acronyms and Abbreviations AC A.D. B.C. BSS COA CPCN CREP DC FAA FERC GIS Grain Belt Express Grain Belt Express Project HVDC I ICC IDNR INAI KCC KDWPT kv MDC MDNR MISO MONHP MW NASS National Register NRCS PJM Project alternating current Anno Domini Before Christ Biologically Significant Streams Conservation Opportunity Areas Certificate of Public Convenience and Necessity Conservation Reserve Program direct current Federal Aviation Administration Federal Energy Regulatory Commission Geographic Information System Grain Belt Express Clean Line LLC Grain Belt Express Clean Line Project high voltage direct current Interstate Illinois Commerce Commission Illinois Department of Natural Resources Illinois Natural Areas Inventory Kansas Corporation Commission Kansas Department of Wildlife, Parks, and Tourism kilovolt Missouri Department of Conservation Missouri Department of Natural Resources Midcontinent Independent System Operator, Inc. Missouri Natural Heritage Program megawatt National Agricultural Statistics Service National Register of Historic Places Natural Resources Conservation Service PJM Interconnection LLC, Inc. Grain Belt Express Clean Line Project

10 ROW USACE USDA USFWS WRP right-of-way U.S. Army Corps of Engineers U.S. Department of Agriculture U.S. Fish and Wildlife Service Wetland Reserve Program

11 Glossary Alternate Route the route selected by the Routing Team and filed with the Commission as a formal alternate to the Proposed Route. Section (a)(1)(viii) of the Public Utilities Act requires the identification of one or more alternate rights-of-way for the Project as part of the filing (220 ILCS 5/ (a)(1)(viii)). Alternative Routes routes assembled from Potential Route links that were refined after the Public Meetings. The Proposed Route and an Alternate Route are identified as a result of the analysis and comparison of these routes. Conceptual Routes initial routes developed to consider a range of reasonable alignments in the Study Area. The development of Conceptual Routes is the first step in identifying routes based on large-scale opportunities and constraints. constraint areas that should be avoided to the extent feasible and reasonable during the Route Selection Study process. The constraints were divided into two groups based on the size of the geographic area encompassed by the constraint. The first group includes constraints covering large areas of land in the Study Area. The second group of constraints encompasses other features covering smaller geographic areas or pointspecific locations. General Routing Guidelines a set of principles that guide the development of alignments with respect to area land uses, sensitive features, and considerations of economic reasonableness. link the section of a Potential Route located between two nodes. node a common point of intersection between two or more Potential Routes. opportunities areas where the transmission line would have less disruption to area land uses and the natural and cultural environment. Opportunities typically include other linear infrastructure and utility corridors, such as the existing electric and gas transmission network, rail lines, and roads but may also include reclaimed lands or unused portions of industrial or commercial areas. Potential Routes Conceptual Routes are refined into Potential Routes as additional information from agency coordination, public outreach, and ongoing review of the area is obtained and considered. Potential Routes ultimately become Alternative Routes after further refinement following Public Meetings. Potential Route Network all Potential Routes and their interconnection points (nodes). Proposed Route the route identified by the Route Selection Study that is ultimately filed with the Illinois Commerce Commission for approval. The Proposed Route represents the primary right-of-way of the application as referenced in Section (a)(1)(viii) (220 ILCS 5/ (a)(1)(viii)). Public Meeting a public open house meeting in the Illinois Study Area.

12 Refined Potential Route Network as the Potential Route Network is refined, links are modified, removed, or added creating the refined Potential Route Network. The Refined Potential Route Network is then presented to regulators and the public for comment and input. Roundtables community leader meetings. Routing Team the multi-disciplinary team that developed the Conceptual Routes, refined the Potential Routes, analyzed and compared Alternative Routes, and determined the Proposed Route and Alternate Route. The Routing Team s experience includes transmission line route planning and selection, impact assessment for natural resources, land use assessment and planning, cultural resource identification and assessment, impact mitigation, transmission engineering and design, and construction. A list of the Routing Team members, along with a description of their individual role, is in Appendix B. Study Area portions of Kansas, Missouri, Illinois, and Indiana evaluated for placement of the Grain Belt Clean Line Project. Technical Guidelines technical limitations for the Routing Team to follow related to the physical limitations, design, right-of-way requirements, or reliability concerns of the Project infrastructure.

13 Executive Summary Introduction Grain Belt Express Clean Line LLC (Grain Belt Express) proposes to construct a new high voltage direct current (HVDC) transmission line from Ford County, Kansas, to Sullivan County, Indiana. The HVDC line will be approximately 780 miles long and deliver approximately 500 megawatts (MW) of low-cost renewable power to an interconnection with the Midcontinent Independent System Operator, Inc. (MISO) and 3,500 MW of low-cost, renewable power to an interconnection with the PJM Interconnection, LLC (PJM) to serve markets in Missouri, Illinois, Indiana, and states farther east. The HVDC transmission line will connect to the existing grid at three distinct locations. The converter stations for the Grain Belt Project would be constructed 1) near Sunflower Electric Cooperative s Spearville Substation in Ford County, Kansas; 2) near Ameren Missouri s Maywood-Montgomery 345 kilovolt (kv) line in Ralls County, Missouri; and 3) near American Electric Power s Sullivan/Breed Substation (herein after referred to as the Sullivan Substation) in Sullivan County, Indiana. The converter station in Ford County, Kansas, will convert the alternating current (AC) electricity from new wind generators in the local area to direct current (DC) electricity for delivery by the HVDC line. The converter stations in Ralls County, Missouri, and in Clark County, Illinois, will convert DC electricity to AC electricity for delivery to the local AC electric grid. Grain Belt Express retained The Louis Berger Group, Inc., to support the siting, public outreach, and regulatory process for the Project. Together, staff from The Louis Berger Group, Inc., and Grain Belt Express conducted a Route Selection Study to identify a Proposed Route for the Grain Belt Express Project transmission line. The Proposed Route was determined by the Routing Team to be the route that best minimizes the overall effect of the transmission line on the natural and human environment while avoiding unreasonably circuitous routes, unreasonable costs, and special design requirements. Routing Process The Routing Team employed a route selection process that involved iterative phases of information gathering, outreach, route development, and route review and revision. The major phases of route development involved successively narrowing the choices under consideration from the earliest Conceptual Routes, to Potential Routes, to Alternative Routes, and ultimately to the selection of the Proposed Route or as additional information was gathered in each phase. Initial route development efforts started with identifying large area constraints and opportunity features across the entire Project Study Area. Using this information, the Routing Team developed a range of Conceptual Routes, which were approximate alignments that focused the

14 early data gathering, field reconnaissance, and public outreach efforts of the Routing Team. During this phase, Roundtables were held in portions of the Study Area in each county crossed by Conceptual Routes. The Roundtable meetings were held to gather input from local officials, economic development representatives, and community leaders on area constraints, opportunities, and Conceptual Route alignments in those areas that provided the most suitable routing options for the Project. Fifty-seven Roundtable meetings were held across the Study Area. Upon completion of these Roundtables, the Routing Team had collected information from more than 740 community leaders in the Study Area. In Illinois, 14 Roundtables were held, with more than 175 participants attending from more than 20 counties. As the Routing Team continued to collect information, coordinate with regulatory agencies, and gather additional information, the assemblage of Conceptual Routes was narrowed and refined. These refinements ultimately eliminated the Conceptual Routes in the southern and central portions of the Study Area from further consideration due to challenges associated with a range of routing constraints, including: large areas of federal land ownership, large complexes of reservoirs and recreational lakes, dense and interspersed development, and a lack of suitable crossings of the Mississippi River. The remaining routes in the northern portion of the Study Area were considered Potential Routes and extended northeast from Ford County, Kansas; crossed the Missouri River between Kansas City and the Nebraska state line; crossed the Mississippi River north of St. Louis; and continued to the Sullivan Substation, remaining south of Springfield, Illinois. The Potential Routes were further refined and presented to state and local agency officials and the general public at a series of Public Meetings. At the Public Meetings, the Routing Team provided information about the Project and collected feedback to help further refine the Potential Routes. More than 3,160 people attended the 27 Public Meetings in Illinois. During and after the first two rounds of Public Meetings in Illinois, the Routing Team reviewed the Potential Route Network in detail with respect to a variety of environmental, cultural, and land use factors, public input on area constraints near the Potential Routes, and engineering input and removed several links of the Potential Route Network to focus analysis and comparison on those links that had lesser overall impact. The Routing Team compiled the remaining links in the refined Potential Route Network into Alternative Routes. To accommodate a reasonable comparison between Alternative Routes, the Routing Team divided the routes into four distinct segments, Segment 1 (Alternative Routes A and B), Segment 2 (Alternative Routes C G), Segment 3 (Alternative Routes H O), and Segment 4 (Alternative Routes P and Q). Alternative Routes in each segment were compared against one another, and the most suitable route from each segment was selected for compilation of the Proposed Route.

15 Alternatives Analysis and Selection of the Proposed and Alternate Routes The Alternative Routes (Alternative Routes A through Q) were assessed and compared by segment with respect to their potential impacts on natural resources (water resources, wildlife and habitats, special status species, and geology and soils), the built environment (developed land, agriculture, aesthetic resources, and cultural resources), and any noted engineering or construction challenges (alignments/crossings of existing linear features, transportation crossings, and general constructability considerations). Based on that analysis, the Routing Team selected a combination of Alternative Routes B, C, K, and P as the Proposed Route for the Project. This combination of Alternative Routes met the overall goal of minimizing impacts on the natural and human environment along the route, while best utilizing existing linear rights-of-way and avoiding non-standard design requirements. The Proposed Route has a total length of miles across nine counties in Illinois. Alternative Route B was selected in Segment 1. Alternative Route B follows along existing roads and field edges through the heavily cultivated floodplain of the Mississippi River, avoiding impacts to existing pivot irrigation and generally passing between fields that cannot be farmed contiguously (due to existing drainages, elevation changes, roads, etc.). Although Alternative Route A is shorter and more direct across the floodplain, it crosses through the middle of several fields with numerous large irrigation pivots with extension arms that would likely require longer spans and special design requirements to avoid. Alternative Route B, though slightly longer in the floodplain, follows a shorter route through the heavily forested bluffs to the east, which would result in the loss of the least amount of potential special-status bat habitat in an area within 10 miles of known bat hibernacula and timber rattlesnake habitat. In contrast, Alternative Route A crosses farther to the north, taking a longer route through the bluff forests to connect to the routes in Segment 2. Although a portion of this route parallels an existing transmission line, thereby reducing forest fragmentation effects, it clears more forest habitat due to its longer length. Alternative Route A crosses in close proximity to the two more populated places in Segment 1, and passes in close proximity to more houses. In contrast, Alternative Route B approaches the bluffs farther to the south, away from the more populated areas and roads, crosses fewer small parcels, and has fewer residences within both 250 feet (0 residences) and 500 feet (2 residences). Overall, Alternative Route B was chosen as the Proposed Route in Segment 1 because it has less impact on agricultural lands and pivot irrigation systems, special-status species forested habitat, populated areas, and residences. Alternative Route C was selected in Segment 2. Alternative Route C was identified as the Proposed Route in Segment 2 due primarily to its lower potential to impact environmentally sensitive features along its western half and more direct routing, with the least amount of

16 impact on agricultural land use and residential areas along its eastern half, as compared to the other Alternative Routes. Alternative Route C is the shortest route in the segment and follows along distinct-owner parcel boundaries for approximately 49 percent of its total length. It requires the least amount of forest clearing in the area between the Mississippi and Illinois Rivers (the River Hills ecosystem) an important area for habitat conservation due to its greater contiguous forest areas, and an important area for many sensitive species, including the Indiana and northern long-eared bat and timber rattlesnake. Alternative Route C crosses the Illinois River along an existing pipeline crossing, avoiding the creation of a new utility crossing location on the river. In the eastern portion of Alternative Route C, the route closely follows along parcel boundaries for a significant portion of its length, thereby minimizing its impact on agricultural operations. All of the Alternative Routes, except Alternative Route C, cross the estimated obstruction zone for a private airstrip and pass directly adjacent to a large Boy Scouts of America camp, Camp Bunn, near the Village of Hettick. Alternative Route C also has the fewest number of residences within 250 feet (1 residence) and 500 feet (8 residences). Alternative Route K was selected as the Proposed Route in Segment 3. Alternative Route K is aligned primarily along parcel boundaries, crosses the fewest small parcels, and has the fewest residences in close proximity. Alternative Route K avoids crossing through the incorporated area of Wenonah and an area immediately adjacent to an actively expanding rock quarry (and through an area planned for future quarry development). East of Pana, the northern Alternative Routes, in contrast to Alternative Route K, pass through an area of higher density residential development, requiring numerous turns and shifts to avoid individual residences, as well as several notable diversions from the existing 345 kv line once in a parallel alignment. In contrast to the northern Alternative Routes, Alternative Route K is aligned along ownership boundaries to much greater extent and would likely have a lesser impact on residential areas and agricultural lands in the central and eastern portions of Segment 3. The northern Alternative Routes also cross the Hidden Springs State Forest while parallel to the existing line along a steep banked section of Richland Creek, which would likely require significant clearing along both sides of the riparian corridor. Illinois DNR expressed concerns with this crossing, given its potential impacts on sensitive aquatic and riparian habitats, as well as the stability of the steep rocky valley sides of this stream. In contrast to the northern Alternative Routes, Alternative Route K would avoid the Hidden Springs State Forest and impacts to the Richland Creek riparian corridor. Overall, Alternative Route K was identified as the Proposed Route in Segment 3 because it follows parcel boundaries to great extent, while avoiding crossing through a planned quarry expansion, the incorporated area of Wenonah, the Hidden Springs State Forest, and the Lincoln Trail Motosports facility. It also has fewer small parcels crossed (less than 10 acres), fewer residences within 250 feet (0 residences) and 500 feet (29 residences), no public airfield

17 obstruction zone crossings, and the greatest percent of total length along ownership boundaries compared to other Alternative Routes in Segment 3. Alternative Route P was selected as the Proposed Route in Segment 4. In the western portion of Segment 4, Alternative Route P parallels along the south side of the existing 345 kv transmission line from its connection with Alternative Route K to the proposed converter station location. Residential development along the line is relatively limited, and no deviations from the parallel alignment are required to avoid individual residences. In contrast, Alternative Route Q, farther to the south, follows loosely along parcel boundaries with several turns to avoid residences and a pivot. Because Alternative Route P parallels an existing transmission line for its entire length, it would impact forest fragmentation less than Alternative Route Q. East of the proposed converter station location, the two Alternative Routes follow similar paths; however, Alternative Route P would have the least impact on existing pivot irrigation systems. Alternative Route P is selected as the Proposed Route in Segment 4 because it is parallel to an existing high-voltage transmission line for its length with no deviations and would have less impact to pivot irrigation facilities, residences, and forest fragmentation. The combination of Alternative Routes B, C, K, and P comprise a Proposed Route for the Project that best minimizes the overall effect of the Grain Belt Express transmission line on the natural and human environment while avoiding unreasonably circuitous routes, unreasonable costs, and special design requirements. The Routing Team recommends a combination of Alternative Routes A, G, a slightly modified L, and Q as the Alternate Route for the Project. The Alternate Route has a total length of miles across nine counties in Illinois, less than 1 percent longer than the Proposed Route. The Routing Team considers this route to adequately meet the overall goal of minimizing impacts on the natural, human, and historic resources, while making use of existing divisions of land, avoiding non-standard design requirements, and being completely distinct from the Proposed Route per Illinois statute. The latter of these requirements required a slight modification to Alternative Route L. The proposed modification shifts a small 2-mile segment of the route 0.5 mile to the east to ensure the route alignment is not coincident with any portion of the alignment of the Proposed Route. This small modification follows along existing divisions of land and would result in no additional impacts beyond those of the original alignment, ensuring consistency with the analysis presented in this study. Although the Routing Team considers the Proposed Route to be the best assemblage of the Alternative Routes, the Alternate Route was also developed through the same methodology, integrating input from government agencies, local officials, and the general public into the route development, analysis, and selection process. Like the Proposed Route, Alternative Routes A, G, L, and Q were continually revised and refined through multiple iterative rounds of selection

18 through the Conceptual and Potential Route development phases, engineering reviews, and comparative assessment from the Routing Team. As such, the Routing Team determined the Alternate Route to be a viable Alternate to the Proposed Route for the Grain Belt Express Project. The combination of Alternative Routes A, G, L, and Q comprise an Alternate Route for the Project that is reasonable and sound because: 1) the selection of the Alternate Route followed the same methodology as the Proposed Route, integrating input from government agencies, local officials, and the general public into the route development, analysis, and selection process; 2) the Alternate Route abides by the routing guidelines and does a reasonable job of minimizing the overall effect of the Grain Belt Express transmission line on the natural and human environment, while avoiding unreasonably circuitous routes, unreasonable costs, and special design requirements; and 3) the Alternate Route is a completely separate route from the Proposed Route with no coincident portions.

19 1. Introduction 1.1 Project Overview Grain Belt Express Clean Line LLC (Grain Belt Express) proposes to construct a new high voltage direct current (HVDC) transmission line from Ford County, Kansas, to Sullivan County, Indiana. The HVDC line will be approximately 780 miles long and deliver approximately 500 megawatts (MW) of power to an interconnection with the Midcontinent Independent System Operator, Inc. (MISO), and 3,500 MW of power to an interconnection with the PJM Interconnection, LLC (PJM), to serve markets in Missouri, Illinois, Indiana, and states farther east. The HVDC transmission line will connect to the existing grid at three distinct locations. The converter stations for the Grain Belt Express Clean Line Project (Grain Belt Express Project or Project) will be constructed 1) near Sunflower Electric Cooperative s Spearville Substation in Ford County, Kansas; 2) near Ameren Missouri s Maywood-Montgomery 345 kilovolt (kv) line in Ralls County, Missouri; and 3) near American Electric Power s Sullivan/Breed 345 kv Substation (herein after referred to as the Sullivan Substation) in Sullivan County, Indiana. The converter station in Ford County, Kansas, will convert the alternating current (AC) electricity from new wind generators in the local area to direct current (DC) electricity for delivery by the HVDC line. The converter stations in Ralls County, Missouri, and in Clark County, Illinois, will convert DC electricity to AC electricity for delivery to the AC electric grid. Together, the HVDC transmission line, converter stations, a series of AC transmission lines that will collect electricity from generators in Kansas (AC Collector System), along with an AC line from the converter station in Clark County, Illinois, to the interconnection point within the PJM grid comprise the Grain Belt Express Project 1.2 Overview of the Regulatory Process Grain Belt Express is seeking approval to own, construct, and operate the HVDC transmission line in each state crossed by the Project: Kansas, Missouri, Illinois, and Indiana. Regulatory approval for the Project has been secured in Kansas and Indiana, and an application has been submitted in Missouri and is currently under review by the Missouri Public Service Commission (Case No. EA ). An application will also be submitted to the Illinois Commerce Commission (ICC) for a Certificate of Public Convenience and Necessity (CPCN) for the portion of the Project in Illinois. This study presents the information used, methodology, and rationale for the selection of the Proposed Route and Alternate Route in Illinois.

20 Once approvals for the Project are received from each state, site-specific permitting and consultation efforts concerning wetlands, cultural resources, highway crossings, and others will be completed with the appropriate state and federal agencies. 1.3 Project Timeline and Routing Process Overview Grain Belt Express began formal development of the Project in July Soon after, Grain Belt Express contracted with The Louis Berger Group, Inc., to support the siting, public outreach, and regulatory processes for the Project. Staff from The Louis Berger Group, Inc., and Grain Belt Express (the Routing Team) began compiling information about the Study Area by coordinating with various regulatory agencies and identifying Conceptual Routes (see Section 2.2, Process Steps and Terminology, for a description of route development) for the Project. In spring 2011, the Routing Team began hosting a series of community leader meetings (Roundtables; see Section 3.3.1) in southern Missouri and Kansas to gather information regarding local area constraints, community concerns, development plans, and other information from county officials, mayors, economic development coordinators, regional planners, environmental organization leaders, and federal and state agency officials. Throughout the summer of 2011, the Routing Team continued to consider routing concepts, coordinate with agencies, and review possible routing options in the field. During winter 2011, the Routing Team developed a range of Conceptual Routes in the Study Area for the Project. By spring 2012, the Routing Team began a series of Roundtable meetings in locations along the northern portion of the Study Area in Kansas, Missouri, and Illinois, as well as in southern Illinois. Fifty-seven Roundtable meetings were held across the Study Area. By the time these Roundtables were completed, the Routing Team had collected information from more than 740 community leaders in the Study Area. In Illinois, representatives from more than 20 counties, totaling more than 175 participants, attended 14 Roundtables. During summer and fall 2012, the Routing Team continued to coordinate with state and federal regulatory agencies concerning constraint areas, routing opportunity features, and potential suitable crossing locations of the Missouri, Mississippi, and Illinois Rivers. The Routing Team continued to review and refine the network of Conceptual Route alignments, and by fall 2012, it had eliminated Conceptual Routes in the southern and central portions of the Study Area and focused its analysis and Potential Route development efforts on the northern portion of the Study Area. The reduced Study Area encompasses the area around Spearville, Kansas; north of the Flint Hills and Kansas City and south of the Nebraska state line; east toward the Mississippi River between St. Louis, Missouri, and Quincy, Illinois; and then east across Illinois (on a general trajectory south of Springfield) toward American Electric Power s Sullivan Substation in Indiana, south of Terre Haute. Numerous Conceptual Routes were formed across the Study Area and

21 multiple Missouri and Mississippi River crossing locations were evaluated to determine reasonable alignments across these rivers into Missouri and Illinois. By late spring 2013, the Routing Team had refined the Potential Routes in Kansas and identified Alternative Routes from the western converter station to the Missouri River. In summer of 2013, the Proposed Route in Kansas was selected. The Proposed Route crosses the Missouri River and enters Missouri south of St. Joseph along the Rockies Express/Keystone Pipeline corridor. This location became the starting point of the Potential Routes under evaluation in Missouri. By late fall 2013, the Routing Team had refined the Potential Routes and identified Alternative Routes from the Missouri River to the Mississippi River. By the spring of 2014, the Proposed Route in Missouri was selected and submitted to the Missouri Public Service Commission. The Proposed Route in Missouri continued east from the Missouri River, passing just south of Salisbury, Moberly, and the Mark Twain Lake, before turning to the northeast to cross the Mississippi River. A range of crossings of the Mississippi River were considered from Hannibal to Clarksville, Missouri. The most suitable crossing point was determined to be approximately 1.5 miles south of the U.S. Army Corps of Engineers (USACE) Lock and Dam 22 near Saverton, Missouri. This crossing location became the starting point of the Potential Routes under evaluation in Illinois. During the spring, summer, and fall of 2014, the Routing Team continually refined the Potential Route Network in Illinois. By winter 2014, the Potential Route Network was refined to a level suitable for an initial presentation to state and federal agencies, local landowners, and the general public (see Section 3.3.2, Public Meetings). In early December, the first of three rounds of Public Meetings was held in Illinois, with individual meetings held in each of the counties with Potential Route segments. More than 1,800 members of the public attended the first round of Public Meetings in Illinois. The attendees were asked to provide comments on the Project and the Potential Routes. Following the first round of Public Meetings in Illinois, the Routing Team reviewed and responded where necessary to hundreds of public comments submitted at the Public Meetings, online, by mail, or by telephone. The Routing Team reviewed input from the public and considered newly identified constraints and sensitive features, areas of concern, and routing preferences, resulting in further refinement of the Potential Routes for the Project. During this period, Grain Belt Express continued coordinating with state and federal regulatory agencies and non-governmental groups associated with historic and natural resources. By early 2015, the newly revised Route Network was presented to state and federal agencies, local landowners, and the general public at a second round of Public Meetings in Illinois, held during the first week of February Following these meetings, the Routing Team again

22 reviewed hundreds of public comments submitted at the Public Meetings, online, by mail, or by telephone. Revisions to the Route Network were made based on new routing information gathered through public and agency input, additional route reconnaissance efforts, and consideration of the characteristics of each route segment. In the weeks preceding the third round of Public Meetings, which were held in March 2015, the Routing Team compiled a series of Alternative Routes from the remaining segments of the Potential Route Network, analyzed them based on a range of quantitative and qualitative factors, and identified a Proposed Route for the Grain Belt Express Project. An Alternate Route to the Proposed Route was also identified as required by Section (a)(1)(viii) of the Public Utilities Act (220 ILCS 5/ (a)(1)(viii)). 1.4 Project Description Line Characteristics The Grain Belt Express Project will be a ±600 kv HVDC transmission line capable of delivering 500 MW of power to the intermediate converter station in Missouri and 3,500 MW of power to the converter station at the American Electric Power s Sullivan Substation. The HVDC transmission line facility will consist of the primary conductors that carry the electricity, metallic return conductors, shield wires that protect the line from lightning strikes, structures that support the conductors and wires, and foundations that support the structures. Grain Belt Express will use single foundation lattice mast and/or steel monopole transmission structures for the straight-line sections of the Project. Steel lattice structures will be used for turning locations, endpoints, or where greater structural support is needed. In limited instances, guyed lattice structures may be used where absolutely necessary. Design specifications and structure types are presented in Appendix A Right-of-Way Characteristics The HVDC portion of the Grain Belt Express Project will be constructed within a 150- to 200- foot-wide right-of-way (ROW). Tall-growing vegetation (taller than 10 feet) will be cleared from the ROW to its full 150- to 200-foot width or as necessary for the safe and reliable operation of the transmission line. Farming and grazing land uses are typically compatible with transmission line ROWs and can continue within the transmission line ROW. Only the area at the base of each structure will be removed from existing land use (roughly acre for a typical monopole or steel lattice mast structure or acre for a typical lattice structure) Converter Stations The Grain Belt Express Project includes three converter stations. A converter station for an HVDC transmission line looks similar to a typical large electric substation with an additional

23 building that contains the converter power electronics in an enclosed environment. Each converter station will require roughly 40 to 60 fenced-in acres and will be located near its point of interconnection to the AC grid. A converter station at the western end, where the wind energy is generated in Kansas, will convert power from AC to DC. The other two converter stations will invert power from DC into AC for delivery to customers through the existing AC electric grid. The Grain Belt Express Project will deliver power to the AC grid in two locations, one in Missouri and one near the Illinois/Indiana border, for injection into the MISO and PJM transmission grids, respectively. The intermediate converter station will be located near the intersection of the existing Ameren Missouri s Maywood-Montgomery 345 kv transmission line and the Proposed Route in Ralls County, Missouri. The eastern converter station will be located in Clark County, Illinois, near the Sullivan Substation, along Ameren s Casey Breed 345 kv line Project Vicinity The Project will be constructed between Ford County, Kansas, and Sullivan County, Indiana (Figure 1-1). Land use in the Project area is dominated by a combination of rural agricultural land uses (active farm and ranch lands) in the west and along the north of the Project area, with a progressive transition to more forested landscapes farther east and south in Missouri and Illinois. Four major rivers, the Arkansas, Missouri, Mississippi, and Illinois, cross the area and provide water for agricultural lands. Major cities in the Project area from west to east include Dodge City, Wichita, and Topeka, Kansas; St. Joseph, Kansas City, Springfield, Columbia, Jefferson City, and St. Louis, Missouri; and Quincy and Springfield, Illinois. Major large land area attractions and recreational resources within the Project area include the Flint Hills (Tall Grass Heartland in Kansas); the Mark Twain and Shawnee National Forests in Missouri and Illinois, respectively; Mark Twain Lake in Missouri; the general region of the Ozarks, which contains forests; and a widely distributed array of federally and state-managed reservoirs that provide outdoor recreation, flood protection, and water sources.

24 Figure 1-1. Project Vicinity Map

25 2. Routing Process 2.1 Goal of the Route Selection Study The Route Selection Study was conducted to identify the route for the Grain Belt Express Project. The overall goal of this Route Selection Study is to gain an understanding of the opportunities and constraints in the Study Area, develop feasible Alternative Routes, evaluate potential impacts of the Alternative Routes, and identify a Proposed Route and Alternate Route for the Project. The Proposed Route is defined as the route that minimizes the overall effect of the transmission line on the natural and human environment, avoids unreasonably circuitous routes and unreasonable costs, and minimizes special design requirements.

26 2.2 Process Steps and Terminology The route development process is inherently iterative with frequent additions or deletions of line segments and revisions to existing alignments as new constraints and opportunities are identified and inputs are received. Because of the iterative nature of the route development process, the Routing Team uses specific vocabulary to describe the routes at different stages of development. Initial route development efforts start with identifying large area constraints and opportunity features within the Study Area, which encompasses the endpoints of the Project and areas in between. These areas are typically identified using a combination of readily available public data sources. The Routing Team uses this information to develop Conceptual Routes adhering to a series of general routing and technical guidelines (see Section 2.4, Routing Guidelines). Efforts are made to develop Conceptual Routes throughout the Study Area to ensure that all reasonable alignments are considered. Alignments are approximate at this stage, but are revised after ongoing review and analysis and with input from the public, governmental entities, and other stakeholders. During this step, Roundtables are held in each county crossed by a Conceptual Route to gain more information about the Study Area. As the Routing Team continues to collect information, coordinate with regulatory agencies, and gather additional site-specific information, Conceptual Routes are refined. The revised Conceptual Routes are Potential Routes. Study Area Data Gathering Conceptual Routes Potential Routes

27 Where two or more Potential Routes intersect, a node is created, and between two nodes, a link is identified. Together, the Potential Routes and their interconnected links are referred to as the Potential Route Network. The links are numbered for identification, and evaluated both independently and collectively. As the Routing Team continues to gather information and review the links of the Potential Route Network, links are modified, removed, or added. Based on this iterative process, a Refined Potential Route Network is developed and presented to government officials and the public at Public Meetings. Attendees provide input on Potential Route links and additional site-specific information for the Routing Team to consider. As public input is incorporated, the links of the Potential Route Network are further refined and compared, and a selection of the most suitable links is assembled into Alternative Routes. Alternative Routes are routes that begin and end at similar locations for direct comparison. Potential impacts are assessed and compared with land uses, natural and cultural resources, and engineering and construction concerns. Ultimately, through analysis and comparison of the Alternative Routes, a Proposed Route is identified. The Proposed Route is the route that minimizes the overall effect of the Project on the natural and human environment, while avoiding circuitous routes, extreme costs, and non-standard design requirements. [Note: In Illinois, a viable Alternate Route is also identified by the Routing Team and filed with the Commission as a formal alternate to the Proposed Route.] Potential Route Network Refined Potential Route Network Alternative Routes Proposed Route *Please note the above graphics are for illustration purposes only and do not reflect actual routes.

28 2.3 Routing Team Members A multidisciplinary Routing Team performed the Route Selection Study. Members of the Routing Team have experience in transmission line route planning and selection, natural resource impact assessment, land use assessment and planning, cultural resource identification and assessment, impact mitigation, transmission engineering and design, and construction. Appendix B lists the Routing Team members and their respective areas of responsibility. The team worked together during the Route Selection Study to: Define the Study Area Develop Routing Guidelines Collect and analyze environmental and design data Identify routing constraints and opportunities Consult with resource and permitting agencies Develop and revise the route alternatives Analyze and report on the selection of a Proposed Route 2.4 Routing Guidelines As noted previously, the overall goal of the Route Selection Study is to identify a Proposed Route that minimizes the overall effect of the transmission line on the natural and human environment, avoids unreasonably circuitous routes and unreasonable costs, and minimizes special design requirements. A set of routing guidelines help the Routing Team reach that goal by setting forth principles that guide the development of alignments considered in the study. The Routing Team considered two types of guidelines: General Routing Guidelines and Technical Guidelines. General Routing Guidelines establish a set of principles that guide the development of alignments with respect to area land uses, sensitive features, and considerations of economic reasonableness. Technical Guidelines provide the Routing Team with technical limitations related to the physical limitations, design, ROW requirements, or reliability concerns of the Project infrastructure General Routing Guidelines The following are General Routing Guidelines used for the Grain Belt Express Project: a. Maximize the separation distance from and/or minimize impacts on residences

29 b. Maximize the separation distance from and/or minimize impacts on schools, hospitals, and other community facilities c. Avoid the need for removal of existing barns, garages, commercial buildings, and other nonresidential structures d. Minimize impacts on agricultural use, including the operation of irrigation infrastructure e. Avoid crossing cemeteries or known burial places f. Minimize crossing designated public resource lands, such as national and state forests and parks, large camps and other recreational lands, historic resources and sites, and state designated wildlife management areas g. Minimize crossing large lakes, major rivers, and large wetland complexes h. Minimize impacts on critical habitat, protected species, and other identified sensitive natural resources i. Minimize substantial visual impacts on residential areas and public resources j. Minimize route length, circuity, cost, and special design requirements Technical Guidelines The following are Technical Guidelines used for the Grain Belt Express Project: a. Minimize the crossing of 345 kv and 500 kv transmission lines b. Minimize paralleling corridors with more than one existing 345 kv or above circuit c. Maintain 200 feet of centerline-to-centerline separation when paralleling existing transmission lines of 345 kv or above d. Maintain 150 feet of centerline-to-centerline separation when paralleling 138 kv or lower voltage transmission lines e. Minimize turning angles in the transmission line greater than 45 degrees f. Minimize placing structures on sloping soils of more than 30 degrees (20 degrees at angle points) g. Avoid underbuild arrangements with existing AC infrastructure h. Maintain a safe operational distance from existing wind turbines 2.5 Data Collection The following sources of information were used to support the analysis in the Route Selection Study.

30 2.5.1 GIS Data Sources The study made extensive use of Geographic Information System (GIS) software (ArcMap v10.2) and data sources. Information from existing GIS data sets was gathered from many sources, including federal, state, and local governments (see sources in Appendix C). Much of this information was obtained from official agency GIS data access websites and government agencies. The Routing Team also created and corrected GIS data by digitizing information from paper-based maps, completing aerial photograph interpretation, conducting interviews with stakeholders, and completing field reconnaissance Digital Aerial Photography Aerial photography is an important tool for route selection. The primary sources of aerial imagery used in the route identification, analysis, and selection effort for the Project include: National Agricultural Imagery Program s color aerial photography (2012, 2014) Google s Google Earth color aerial photography Microsoft s Bing Aerial Imagery service Aerial photography from these sources was viewed using GIS software (ArcMap v10.2). A variety of information was collected through photo interpretation of these imagery sources in GIS, such as the location of residences, mining operations, airfields, and existing transmission lines. Features identified through aerial photograph interpretation were verified through route reconnaissance to the extent practical Route Reconnaissance Routing Team members examined Potential Routes by automobile from points of public access and correlated observed features to information identified on aerial photography, U.S. Geological Survey 7.5-minute topographic maps in digital format, road maps, and the range of GIS sources. Prior to field reconnaissance, some features, such as residences, outbuildings, recognized places of worship, cemeteries, and commercial and industrial areas, were identified and mapped in GIS using aerial photography. Residences were categorized as either occupied or unoccupied. In instances where it was unclear whether or not a residence was occupied, it was assumed to be occupied. These features were then verified during field reconnaissance and added to the GIS database using laptops running GIS software supported by real-time global positioning system information. In addition to automobile reconnaissance, the Routing Team also conducted a helicopter review of the Alternative Routes from the air to determine the presence or absence of features not visible from the ground-based reconnaissance efforts.

31 2.6 Routing Constraints The Routing Team identified and mapped routing constraints in the Study Area. These constraints were defined as areas that should be avoided to the extent feasible during the Route Selection Study process. The constraint list was revised as the Routing Team developed greater familiarity with the Study Area and gathered additional data through Agency Meetings and Public Meetings. The constraints were divided into two groups based on the size of the geographic area encompassed by the constraint. The first group included constraints covering large areas of land in the Study Area. The Routing Team considered large-area constraints as unfavorable or incompatible for developing routes and avoided those areas to the extent possible. The list of large-area constraints consists of: a. Urban areas, including cities, towns, villages, and other built-up areas b. Federal lands, including national forests, national parks, national wildlife areas, lands administered by USACE for flood control, and military facilities c. State forest park lands and wildlife management areas d. Conservation lands and lands designated for their natural importance or scenic value e. Native American reservation lands f. Areas near airports and airstrips g. National Register of Historic Places (National Register), Historic Districts and adjacent areas h. Large recreational sites i. Large lakes and reservoirs that could not be spanned with the structures set well back from the shores j. Large wetlands or wetland complexes The second group of constraints encompasses other features covering smaller geographic areas or point-specific locations. Conceptual Routes were developed to avoid large-area constraints. The alignments were then refined to create Potential Routes that avoided, to the extent possible and practical, point-specific constraints, including but not limited to: a. Individual occupied 1 residences (including houses, permanently established mobile homes, and multi-family buildings) 1 See Section 2.5.3, Route Reconnaissance.

32 b. Commercial and industrial buildings, or areas within commercial properties with current plans for construction and development c. Quarries and areas within their control planned for future mining operations d. Irrigation facilities e. Recorded and designated historic buildings and sites, including any specified buffer zone around each site f. Recorded sites of designated threatened, endangered, and other rare species or unique natural areas and the specified buffer zone around each site g. Small wetlands or waterbodies h. Developed recreational sites or facilities i. Communication towers j. Designated scenic vista points 2.7 Routing Opportunities Routing opportunities were identified by the Routing Team as locations where the proposed transmission line might be located with less disruption to surrounding land uses and the natural and cultural environment. Opportunity features typically included other linear infrastructure and utility corridors, such as existing electric and gas transmission networks, rail lines, and roads, but may also include reclaimed lands or unused portions of industrial or commercial areas, if compatible. Existing transmission lines were considered an opportunity if they were aligned in a suitable direction. Paralleling existing transmission lines is a common practice used when routing new transmission lines and is supported by many state utility commissions, state and federal regulatory agencies, and the Federal Energy Regulatory Commission (FERC 1970). Paralleling existing linear utilities consolidates utility corridors by placing a new land use feature in close alignment with an existing similar land use feature, thereby avoiding the fragmentation of existing land uses and habitats through an area. In addition, paralleling existing transmission lines can reduce the overall impact of the new transmission line on visually sensitive areas (e.g., historic sites and outdoor recreational areas), avian resources, and airfield flight zones because any impacts of the new line are considered with respect to the impacts of the existing line. In these areas, the impacts of the new line are considered incremental to the existing impacts, rather than as completely new impacts in otherwise unimpacted areas. Major pipelines were also considered an opportunity feature, especially in areas where there were no existing transmission lines and in forested areas where the pipeline has an established and cleared ROW. Like transmission lines, pipeline ROWs are cleared linear corridors of

33 existing disturbance where construction of buildings and other non-pipeline facilities are prohibited. Paralleling these features consolidates linear ROWs with similar construction and use limitations, thereby avoiding the fragmentation of land uses through an area. Roads are typically considered as a logical linear opportunity for planning transmission lines and are commonly paralleled by lower voltage transmission and distribution lines. However, for higher voltage lines with larger structures and longer spans, alignments along roads often conflict with the residential and commercial development common along roadways, with future transportation corridor expansion, and with highway ROW and clearance requirements. Rail lines present a similar type of opportunity feature, but also one that can be limited by adjacent development. Communities and industrial facilities (including grain elevators) are often located along rail lines, making it difficult to closely parallel them with a transmission line for any significant distance. However, where feasible, both roads and rail lines were considered. In addition to existing linear infrastructure, the grid-based section lines of the public land survey system and the parcel boundaries that further dissect each section (referred to as section/parcel boundaries) also served to guide the development of alignments along logical divisions of land ownership and use. The Routing Team aligned routes along section/parcel boundaries in the absence of, or as an alternative to, parallel alignments along existing linear infrastructure if existing land use would be more affected by the Project. This was most relevant in farmed areas, where farming operations extend to the edge of the property boundary.

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35 3. Agency and Public Outreach 3.1 Regulatory Agency Coordination The Routing Team contacted numerous federal, state, and local agencies to gather information for the route planning process. Coordination efforts focused on introductions to the Project, data gathering, and discussions concerning likely permitting and consultation requirements. Discussions were held with the Illinois Department of Agriculture, Illinois Department of Natural Resources (IDNR), Illinois State Historic Preservation Agency, Illinois Environmental Protection Agency, Bureau of Water, Illinois Department of Transportation, U.S. Fish and Wildlife Service (USFWS), USACE, and other non-governmental organizations. These agencies and non-governmental organizations were asked to review the Potential Route Network and the Mississippi and Illinois River crossing locations and to provide any information that would be helpful in selecting a preferred crossing and route. The outcome of these discussions helped to select the final crossing location and Proposed Route and is discussed in Section 4.3. The agencies consulted are provided in the list below. Copies of correspondence with federal offices and state agencies in Illinois are provided in Appendix D. Federal Agency and Regulatory Authorities: U.S. Environmental Protection Agency, Region 7 U.S. Fish and Wildlife Service - Midwest Region, Columbia Ecological Services Office - Mountain-Prairie Region, Kansas Ecological Services Field Office - Midwest Region, Rock Island Ecological Services Field Office - Midwest Region, Marion Ecological Services Sub-Office U.S. Army Corps of Engineers - Kansas City District (Kanopolis Office) - Rock Island District - Louisville District - St. Louis District - Tulsa District

36 National Park Service - Fort Larned National Historic Site - National Historic Trails California National Historic Trail Santa Fe National Historic Trail Oregon National Historic Trail Natural Resources Conservation Service State Agency and Regulatory Authorities: Missouri - Missouri Public Service Commission - Missouri Department of Conservation - Missouri Department of Transportation - Missouri Department of Natural Resources State Historic Preservation Office Division of Environmental Quality Kansas - Kansas Corporation Commission - Kansas Department of Transportation - Kansas Department of Wildlife, Parks and Tourism - Kansas Historical Society - Kansas Forest Service - Kansas Department of Agriculture - Kansas Department of Health and Environment Illinois - Illinois Department of Agriculture - Illinois Environmental Protection Agency, Bureau of Water - Illinois Department of Natural Resources, Historic Preservation Office - Illinois Department of Natural Resources - Illinois Department of Transportation - Illinois Nature Preserve Commission - Illinois State Farm Service Agency

37 Indiana - Indiana Utility Regulatory Commission - Indiana Department of Environmental Management - Indiana Department of Natural Resources Division of Fish and Wildlife Division of Historic Preservation and Archeology 3.2 Non-governmental Organizations In addition to state and federal agencies, the Routing Team coordinated with several natural resource and historic conservation groups during the process. These contacts provided valuable additional information sources for identifying sensitive natural resource habitats and historic resources in the Study Area. These groups included: The Nature Conservancy, Missouri, Kansas, and Illinois Chapters Illinois Farm Bureau Ducks Unlimited of Illinois Ducks Unlimited of Missouri Prairie Rivers Network (National Wildlife Federation) National Pony Express Association Oregon-California Trails Association Sierra Club, Kansas, Illinois and Missouri Chapters Environmental Law and Policy Center Audubon Missouri Missouri Coalition for the Environment Missouri Prairie Foundation Environment Missouri Illinois Environmental Council Illinois Natural Resources Defense Council

38 3.3 Community Outreach Activities The Routing Team led a community outreach program designed to educate the public about the purpose and benefits of the Project, inform community leaders and the public about the regulatory process and Project timeline, and gather information to assist the siting effort. An important part of the outreach program was to identify key community leaders in each county in which the line may be constructed. To this end, Grain Belt Express staff met with local county officials throughout the Study Area early in the development process to introduce the Project and identify key planning, economic development, and community leaders in each county. These contacts provided insight into local planning issues and development efforts. Two types of public outreach meetings were conducted for the Grain Belt Express Project: Roundtables and Public Meetings. The Routing Team planned meeting locations within the Study Area so that potential attendees would be within a 30-mile radius of at least one meeting location Roundtables The main goal of the Roundtables was to coordinate with and gain valuable information from community leaders in each county in the Study Area. These community leaders included local, county, and municipal elected officials; local government planners; community and business leaders; economic development experts; local utilities and cooperatives; and federal and state agency officials. At each Roundtable, members of the Routing Team presented an overview of the Project and described the routing process. After the presentation, attendees and members of the Routing Team broke into small working groups to review aerial maps of the Study Area counties. Attendees were encouraged to write on the maps and to provide and verify specific information about sensitive features, planned development, and existing infrastructure in their communities. Attendees were also encouraged to draw route suggestions on the aerial maps for the Routing Team to consider during the routing study, based on current and future opportunities and constraints. After the meetings, the identified constraints and suggested routes were digitized, reviewed, and/or incorporated into the routing process. In Illinois, 14 Roundtables were held with over 175 participants from more than 20 counties. The Roundtables provided the Routing Team with an avenue to gain community perspectives on new or planned infrastructure in relation to the community member s county or jurisdiction through face-to-face communication. The community leaders at the Roundtables helped to identify large area constraints or opportunities in their counties or jurisdictions. Community leader input also helped identify potential future land use plans, such as the construction of new water storage facilities; communication towers; or new industrial, commercial, or residential development; and they helped identify and verify the approximate location of existing features, such as historic sites, mining activities, communication towers, airstrips, schools, and churches.

39 The Routing Team considered data provided by community leaders at the Roundtables in its route development and selection efforts Public Meetings Grain Belt Express hosted three Public Meetings in each county crossed by the Project to present information about the Project, present Potential Routes, and seek input from the general public. The meetings were held in week long rounds, during which one meeting was held in each county where the Project may be located. The first round of Public Meetings was held in the first week of December 2014 (1 st through the 5 th ), the second in the first week of February 2015 (2 nd through the 6 th ), and the third in the first week of March 2015 (2 nd through the 6 th ). Approximately 3,160 recorded attendees came to the 27 Public Meetings in Illinois. Notification for the Public Meetings included individual mailings sent to landowners, newspaper advertisements, coordination with local community leaders, and posts on the Project website. Mailings were sent to property owners (as identified in the local county tax and parcel information received from each county) within a planning corridor surrounding each link of the Potential Route Network. The planning corridor served to identify those landowners with the greatest potential to be directly affected by the Project. The planning corridor width was greatest during the first round of meetings (approximately 2.5 miles centered on the links of the Potential Route Network) to account for the greater likelihood of identifying unknown constraints, resulting in revisions to the Potential Routes within the Study Area. The planning corridor was narrowed for the second and third rounds (to approximately 1 mile in width) to account for the decreased likelihood of identifying new constraints requiring significant route revisions. Also, portions of the planning corridors that included major developed and/or incorporated areas were typically not included in mailing lists because these areas were not suitable for route development, and the intent of the notification effort was to invite landowners with property that may be directly affected by the Project. Almost 17,000 invitations were sent to notify landowners about the meetings. Copies of the invitations can be found in Appendix E. At each Public Meeting, members of the Routing Team greeted and signed in meeting attendees. At sign-in, attendees were provided with a comment card and asked to fill out the top of the card. The comment card was perforated, with the top portion requesting information such as attendees name(s), address, telephone number, and address. After the attendee completed the top portion, the top of the card was removed to document each individual s attendance. The lower portion of the comment card included several questions for attendees to answer, including questions about potential constraints and potential opportunity areas, and a space to write in general comments about the Project. Attendees were encouraged to turn in the bottom portion prior to leaving the meeting, but were also provided the opportunity to mail comments back to the Routing Team. The upper and lower portions of the comment card

40 were labeled with the same unique number to identify the attendee. In this way, landowner attendance was tracked, and once filled out and submitted, the lower body of the comment card could be linked back to the individual landowner s contact information. After attendees signed in, they were given a guided tour of the Project presented on a series of poster boards arranged on easels. The tour provided information regarding the purpose of the Project, Project benefits, the routing process and criteria, physical characteristics of the line, and easement and compensation information. Information about agricultural impact mitigation was also provided for interested parties. Guided tours typically lasted about 15 minutes and were conducted in small groups to allow attendees to ask questions and receive immediate answers from representatives of the Routing Team. At the end of the tour, Routing Team representatives provided assistance to attendees in locating their property or other features of concern on aerial photography maps that displayed the array of Potential Route links under consideration. Each map presented a specific portion of the line with information on identified constraints, land areas, and existing infrastructure presented at a scale of 1 inch = 1,000 feet. Participants were encouraged to document the location of their houses, places of business, areas of concern on their properties, or other sensitive resources on the printed maps. Routing Team members worked with landowners to ensure that each comment or group of comments provided by an attendee was also referenced to the number on the attendee s individual comment card by recording it on or next to the attendee s comments on the map. One or two digital mapping stations were also provided at each Public Meeting to allow attendees the opportunity to find their properties and document their input directly in the GIS database. Each digital mapping station was run by a GIS technician and contained all of the data presented on the printed maps and a full parcel database to help search for parcels that owners could not find on the printed maps. Analysis of Public Comments After the Public Meetings, all the maps used to collect comments were scanned, georeferenced, and integrated into the GIS database. The locations of specific comments provided by attendees, denoted by the commenter s unique comment card identification number, were digitized within the mapping program and linked to the information provided on the individual s complete comment card. All comments received via the comment cards were recorded and categorized in a database for review and correlation with mapped comment locations during the routing revision process. Generally, the members of the public who attended the Public Meetings helped to identify small area constraints or opportunities on their properties or in their communities. Meeting attendees provided specific information regarding the location, or planned location of features

41 such as residences, barns or outbuildings, irrigation facilities, cemeteries, schools, airfields, historic markers, and other culturally significant locations. They also provided information regarding current land use such as agricultural uses, rangeland, and recreational areas. More than 900 comment cards were received following the Public Meetings, and members of the Routing Team responded to individuals posing a question or specific concern if a response was requested. Comments were also collected from the public through the Project website, mailed letters, , and a toll-free phone number. The maps with the Potential Routes presented at the Public Meetings were also posted online, so stakeholders could review the Potential Routes and provide comments even if they were unable to attend the Meetings. Comment cards also included a question related to opportunity features. In developing Potential Routes, the Routing Team considered paralleling linear features, including existing transmission lines, pipelines, parcel boundaries, roads, and rail lines. To gain greater perspective on these opportunity features, comment cards at the first round of meetings included a question inquiring which types of features the individual preferred for parallel alignments. Each comment card was scanned and entered into a database that enabled the Routing Team to track parallel preferences, as well as concerns, for each individual who provided a card.

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43 4. Route Development As described in Section 2.2, the route development effort is an iterative process beginning with identification of Conceptual Routes within a Study Area that are further refined to become a network of Potential Routes. Conceptual Routes were initially developed and compared across all four states to identify the most suitable location for the Project from a high level. The Conceptual Routes were then further refined state by state to become Potential Routes. The network of Potential Routes was then analyzed, compared, refined, and ultimately assembled into Alternative Routes. Finally, comparative potential impacts were evaluated for each Alternative Route to identify a Proposed Route (as well as a statutorily required Alternate Route in Illinois). To date, the Proposed Route in Kansas has been approved (KCC 2013, Docket # 13-GBEE-803-MIS), and the Proposed Route in Missouri is currently under review by the Missouri Public Service Commission (Case No. EA ). (Approval of the Indiana portion of the route by the Indiana Utility Regulatory Commission is not required.) This study documents the methods, information, and rationale for the selection of the Proposed Route and Alternate Route in Illinois. The following sections provide discussions of each phase of route development and present a summary of routing decisions and analysis that led to the subsequent refinement stage. 4.1 Study Area The Study Area for the Grain Belt Express Project is generally defined as the geographic area encompassing the two end-point converter stations in Ford County, Kansas, and Clark County, Illinois (and the nearby PJM interconnection point in Sullivan County, Indiana), and logical interconnection locations for the third, intermediate converter station near the Missouri/Illinois border in Ralls County, Missouri (Figure 4-1). The presence and extent of certain relevant resources within the Study Area were also considered while delineating the Study Area boundary. One of the major factors that guided the definition of the Study Area boundary is the presence of opportunity features, particularly existing linear ROWs, including electric transmission line and pipeline ROWs. Incorporating the location and trajectory of existing linear utility corridors in the delineation of the Study Area ensures that Potential Routes parallel to existing linear infrastructure are considered. Although the term Study Area boundary suggests that the Study Area is maintained throughout the study process as a fixed boundary, in practice this was not the case. As the routing study progressed, the Routing Team identified additional opportunities and constraints, and the Study Area boundary was modified, as appropriate.

44 Figure 4-1. Generalized North, Central, and Southern Paths within the Study Area

45 4.2 Conceptual Route Development in the Study Area Conceptual Routes are the first step in the route development effort. As the name suggests, Conceptual Routes are developed as broad routing concepts that typically avoid large area constraints or incorporate notable opportunity features in the Study Area. In practice, the transition from Conceptual Routes to Potential Routes falls along a continuum. However, for the purpose of this study and to provide for clarity in referencing different decision phases of the effort, routing decisions that impacted route planning across all four states are presented under the Conceptual Route development process. The Routing Team developed an array of initial Conceptual Routes for the Grain Belt Express Project in Kansas, Missouri, Illinois, and Indiana. The following sections provide a summary of the Conceptual Routes that the team considered, including the basis for the routing concept, key constraints and opportunities encountered, and the decision whether to eliminate or continue refinement of each Conceptual Route. For simplicity and clarity, the Conceptual Routes are grouped based on their relative geography in the Study Area (see Figure 4-1). Conceptual Routes in the northern portions of the Study Area followed paths that led north of Kansas City and St. Louis to reach the eastern converter station location. Conceptual Routes in the central portion of the Study Area generally followed paths north of Wichita, south of Kansas City, and north of St. Louis, and Conceptual Routes in the southern portion of the Study Area generally followed a trajectory either north or south of Wichita and the reservoir system in Missouri but crossed into Illinois south of St. Louis Conceptual Routes Northern Portion of the Study Area Conceptual Routes along the northern portion of the Study Area were developed to consider alignments that crossed the Missouri River between Kansas City and the Nebraska state line, crossed the Mississippi River north of St. Louis, and remained south of Springfield, Illinois, to continue to the Sullivan Substation (Figure 4-2). Residential density along the northern Conceptual Routes is relatively minimal, and most large area constraints were readily avoidable. However, three major river crossings, sensitive grassland habitats, and historic sites and trails represented notable challenges to the route development effort through this portion of the Study Area. Large area constraints in the northern portion of the Study Area in Kansas include: multiple federally owned reservoirs and state conservation lands; two national wildlife refuges; several army bases; and the cities of Topeka, Lawrence, Salina, Hays, and Great Bend. In addition, the Flint Hills Ecoregion, one of the largest intact areas of tallgrass prairie in North America, occupies a significant portion of the Study Area in Kansas. In Missouri, large area constraints include: developed areas along U.S. Highway 36 and numerous conservation easements associated with the Grand River and Swan Lake National Wildlife Refuge, Mark Twain National

46 Wildlife Refuge, Thomas Hill Reservoir, Mark Twain Reservoir, the Missouri National Guard Macon Training Site, two state parks, and several state conservation areas. In Illinois, dense development around Quincy, Springfield, and Effingham presented challenges for routing the Project, as well as conservation easements along the Illinois River, the Meridosia National Wildlife Refuge, and Lake Shelbyville. Opportunity features in the northern portion of the Study Area include the existing network of transmission lines and an array of interstate pipelines passing from southwest to the northeast in Kansas and from west to southeast in Missouri. Section lines and parcel boundaries also served to guide the development of route alignments to follow along ownership boundaries when possible. Several rail lines and state or federal highways were also considered in the initial development of Conceptual Routes; however, restrictions on overhanging state highway ROW combined with the close relationship between roads, rail, and commercial or residential development limited the development of reasonable alignments along many of these features. The Routing Team considered a variety of different route options to exit the western converter station in Kansas toward the northern portion of the Study Area. Route development in this area of Kansas is encumbered by extensive farmlands and irrigation facilities; the physical congestion of existing wind generation facilities, transmission lines, substations, and residences; and sensitive lesser prairie-chicken habitat that surrounds the Spearville area along its eastern and northern periphery. However, several suitable route options were developed along section/parcel boundaries to the north and east and along existing transmission lines to the northeast toward Great Bend. Conceptual Routes north of Great Bend continued either along section/parcel boundaries west of U.S. Highway 183, north along an existing 115 kv transmission line near U.S. Highway 281, or northeast along the Natural Gas Pipeline of America pipeline corridor to Concordia. Conceptual Routes were initially developed between Cheyenne Bottoms Wildlife Area and Quivira National Wildlife Refuge but were eliminated from further consideration following agency coordination with the Kansas Department of Wildlife, Parks, and Tourism (KDWPT) and USFWS because of concerns relating to migratory birds and the federally listed endangered whooping crane. In addition, Conceptual Routes initially formed along Interstate (I-) 70 were also eliminated from further consideration due to the frequent diversions required to avoid developed areas along I-70 and in proximity to Fort Riley Army Installation. These routes also cross the Tallgrass Heartland of the Flint Hills, a highly scenic area viewed by 12,000 to 20,000 travelers a day. From Concordia to the Missouri River, three main west-to-east Conceptual Routes were developed with periodic north-to-south interconnections between each route. The Routing Team considered three primary Missouri River crossing locations near St. Joseph, Missouri:

47 Figure 4-2. Conceptual Route Development in the Northern Portion of the Study Area

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49 two on a trajectory north of the city and one to the south. The two northern river crossings were developed at locations that avoided a series of Missouri Department of Conservation (MDC) lands in the floodplain on the eastern bluffs of the river and provided access to parallel a 345 kv line toward St. Joseph. The southernmost crossing was developed to parallel the Rockies Express/Keystone Pipeline corridor from near Fairview, Kansas, up to and across the Missouri River. St. Joseph s residential and commercial development served as the primary constraint on the eastern bluffs 2 of the Missouri River. The steep topography beyond the floodplain quickly shifts land use from floodplain farmland to a combination of forest-covered hillsides and moderate to high-density residential development. The Routing Team initially developed alignments from the two northern river crossings along the Cooper St. Joseph 345 kv line north of the city. However, pockets of residential and commercial development extending northward from the city along I-229 and I-29 prevented suitable parallel alignments along the line through this area. Ultimately, the Routing Team developed routing alignments that diverged from a parallel alignment near Amazonia and continued farther east before angling south to continue along the east side of St. Joseph, paralleling the existing Hawthorne St. Joseph 345 kv transmission line toward the southeastern corner of Buchanan County. The Routing Team developed a network of Conceptual Routes starting at the Rockies Express/Keystone Pipeline crossing of the Missouri River. Similar to the northern crossing, steep topography beyond the floodplain quickly shifts land use from floodplain farmland to a combination of forested hills and moderate density residential development. A network of routes was developed from this southern crossing location eastward, through the farmlands in the Missouri floodplain and into the sporadic residential development along the bluffs and in the subsequent valleys eastward. Conceptual Routes were developed through this area along pipeline or existing transmission lines to the southeast to pass through the residential development along the bluffs and around the community of Agency, Missouri, which is located just east of St. Joseph. Conceptual Routes beyond St. Joseph and east across Missouri were developed around three primary concepts: an alignment based on the section/parcel boundary just south of U.S. Highway 36; a route that continued parallel along the Rockies Express/Keystone Pipeline corridor; and an alignment that paralleled existing transmission lines to the north that looped between St. Joseph, Fairport, Jamesport, Brookfield, and Marceline, Missouri. The Routing Team ultimately removed this latter route alignment from further consideration because the benefits of paralleling the existing transmission lines through this area did not outweigh the likelihood of impacts associated with frequent diversions to avoid residences near Gallatin and 2 A bluff is a steep cliff, or wall or rock or soil that borders a river or its flood plain.

50 Jamesport, multiple transmission line crossings, and crossings of several private and federal conservation easements and Pershing State Park. Extensive federal, state, and private conservation areas line the banks of the Grand River just east of Highway 65. Two breaks in these conservation lands along the river were considered for crossing the Grand River and its floodplain forests. The first crossing was identified just north of the Swan Lake National Wildlife Refuge and south of the Town of Sumner. The second crossing was identified approximately ten miles south along the Rockies Express/Keystone Pipeline corridor. East of the Grand River, Conceptual Routes were developed to avoid the Thomas Hill Reservoir and the conservation lands surrounding it by passing north or south around the reservoir. Conceptual Routes south of Thomas Hill Reservoir paralleled an existing 161 kv transmission line that angles southeast of the reservoir before turning east, just south of Cairo. Conceptual Routes north of Thomas Hill Reservoir avoided conservation lands and the Army National Guard s Macon Training Site, located just east of the reservoir. In Monroe and Ralls Counties, Mark Twain Lake encompasses a large area of land that includes a state park, federal land managed by USACE, and a patchwork of private conservation easements. Conceptual Routes were developed north and south of the lake. Routes developed along the north side connected to potential Mississippi River crossings near Quincy, Illinois and Hannibal, Missouri. Routes that continued south of the lake both through Monroe County and along the Rockies Express/Keystone Pipeline farther south in Audrain County connected to potential river crossings near Hannibal, Louisiana, and Clarksville, Missouri. The Routing Team considered numerous Mississippi River crossing locations during the Conceptual Route development phase, both north and south of St. Louis, from roughly Quincy, Illinois to Grand Tower, Illinois. Conceptual Routes in the northern portion of the Study Area fell within a 75-mile stretch of the Mississippi River from Quincy, Illinois, to Winfield, Missouri. Initial siting efforts focused on locations along the river with existing infrastructure crossings but soon expanded to consider all areas where residential development, sensitive habitats, public lands, and cultural resources were limited. Of the many Mississippi River crossings the Routing Team considered, five potential crossings were identified from which the preferred crossing location was ultimately selected (see Section 4.3.2, Development of the Potential Route Network, for a discussion of Mississippi River crossings). In Illinois, the Routing Team developed a network of Conceptual Routes that continued east along existing transmission and pipeline corridors, and along section/parcel boundaries toward the Sullivan Substation. In general, land use in the area is agricultural with an increasing prevalence of forested lands between the Mississippi and Illinois Rivers and farther south near

51 St. Louis. Major communities in the northern portion of the Study Area in Illinois include Quincy, Jacksonville, Springfield, Chatham, Pana, and Effingham. Minimal or easily avoidable large public land areas exist through this portion of the Study Area, and a range of opportunity features are available to develop Conceptual Routes across the state. However, in general, residential development tends to be higher in the northern portion of the Study Area in Illinois when compared to Missouri or Kansas. At the northern extent of the northern Study Area, Conceptual Routes were developed to consider alignments from a crossing point near Quincy, Illinois, east along the existing Ameren 138 kv transmission lines that head east and south of Meridosia, north of Jackson, and southeast toward Pana. Conceptual Routes in the central portion of the northern Study Area extended from potential river crossings near Hannibal, Missouri (both north and south), and allowed for the consideration of alignments along I-72, portions of the Rockies Express corridor, and along parcel and section boundaries that gradually headed southeast toward Pana. Residential and commercial development along the interstate and the pipeline corridor between Pittsfield, Winchester, and south of Jacksonville, Illinois, made these features challenging for developing reasonable route alignments. Conceptual Routes in the southern portion of the northern Study Area extended eastward from the potential river crossings near Louisiana and Clarksville, Missouri, toward Pana and Oconee, Illinois. These Conceptual Routes were primarily developed along section and parcel boundaries due to a lack of suitable existing east/west linear corridors through this area. The geographic distribution of the Conceptual Routes narrows as the routes continue east of the U.S. Highway 51 (between Pana and Oconee, Illinois) toward the eastern converter station, Indiana state line, and the Sullivan Substation. Through this area, routes were primarily developed to consider alignments along the 345 kv lines running southeast of Pana, and section and parcel boundary alignments immediately south Conceptual Routes Central Portion of the Study Area The central portion of the Study Area consists of those routes that generally followed the most direct path from the western converter station to Sullivan Substation, while still considering various opportunity features and avoiding constraints. As Figures 4-1 and 4-3 show, Conceptual Route development efforts through this portion of the Study Area were greatly affected by almost every major metropolitan area, and its associated suburban development, in the Study Area. The primary path for exiting the western converter station in the central portion of the Study Area was along a 115 kv transmission line to Stafford. One other Conceptual Route was initially considered immediately south of Cheyenne Bottoms but was later eliminated due to concerns from KDWPT and USFWS (see Northern Conceptual Route Discussion).

52 From Stafford, Conceptual Routes either continued northeast to Hutchinson along existing transmission lines or due east along section/parcel boundaries for more than 75 miles to approximately 7 miles south of Newton, Kansas. The routes to Hutchinson continued north along an existing 345 kv line between Hutchinson and the Summit Substation and then east through the Tallgrass Heartland along existing transmission lines. Maintaining parallel alignments along this route became increasingly difficult as residential development adjacent to the existing line increased in the satellite communities south of Topeka and Kansas City. Conceptual Routes from Newton continued either northeast across the Tallgrass Heartland parallel to an existing 345 kv line eventually connecting with the routes described above through Carbondale, Kansas, or east to parallel a 115 kv line across the Tallgrass Heartland. Continuing east of the Tallgrass Heartland, Conceptual Route development became encumbered by development protruding south of Kansas City and the Harry S. Truman Reservoir to the east and south. Attempts were made to develop Conceptual Routes through this area along existing transmission lines that connect the outer Kansas City suburbs of Gardner, Spring Hill, Raymore, and Pleasant Hill and along a pipeline that passes between Waverly, Kansas, and Holden, Missouri; however, these routes were later eliminated due to the spread and density of residential development and the numerous diversions from parallel alignments along transmission lines, pipelines, and section/parcel boundaries necessary to avoid individual residences. East of the Kansas-Missouri state boundary and dense residential development south of Kansas City, the Conceptual Routes split with the northernmost routes following an existing gas pipeline corridor northeast toward Warrensburg, diverting to find a suitable crossing of the Missouri River and picking up the gas line corridor again north of the Missouri River and south of Franklin. The southernmost Conceptual Routes in this area attempted to follow 161 kv transmission lines around the north shores of the Truman Reservoir and Lake of the Ozarks, although frequent diversions from a parallel alignment were necessary due to residential development and recreational areas adjacent to the reservoirs. Additional Conceptual Routes were developed north of the lakes and south of Warrensburg and Sedalia, Missouri. Conceptual Routes following the gas line corridor past Franklin continued north of Columbia and into the northern Conceptual Route area. Increased residential development linking Columbia, Jefferson City, and communities on the north shore of the Lake of the Ozarks and increased conservation land along the section of the Missouri River from Arrow Rock to Jefferson City decreased routing opportunities and suitable crossings of the Missouri River in this area. The Conceptual Routes that were developed followed primarily parcel boundaries or connected sections of existing transmission lines heading east or northeast for relatively short distances. The terrain between the reservoir complex in the south and the Missouri River in the north became increasingly more variable, and land use became more heavily forested as the Conceptual Routes proceeded east into the Ozark Mountains.

53 Figure 4-3. Conceptual Route Development in the Central Portion of the Study Area

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55 The Conceptual Routes just north of the Lake of the Ozarks turned northeast along 69 kv and 138 kv transmission lines toward Jefferson City and Chamois or toward Owensville. Due east from there, the larger metropolitan area of St. Louis dominates the landscape with development extending far to the west and south of the city, preventing the development of Conceptual Routes in these areas. The Conceptual Routes crossed the Missouri River by Chamois and angled northeast across an increasingly agricultural landscape when compared to the Ozark region to the south. As the Conceptual Routes approached the Mississippi River, the Routing Team identified existing transmission line crossings near Bolter Island and Iowa Island, due north of St. Charles. Conceptual Routes using existing transmission line crossings closer to St. Louis were not feasible due to the density of residential and commercial development outside of St. Louis and significant federal, state, and private conservation lands around the confluence of the Missouri, Mississippi, and Illinois Rivers. Conceptual Routes in the central portion of the Study Area in eastern Missouri continued north to blend into the northern portion of the Study Area or crossed the Mississippi River at locations not occupied by public lands or historic communities. East of the Mississippi and Illinois Rivers, the Conceptual Routes converged south of Litchfield, Illinois, to parallel existing 345 kv transmission lines northeast toward Pana, Illinois, in the northern portion of the Study Area or east toward the eastern converter station, staying north of Effingham and south of Charleston, Illinois Conceptual Routes Southern Portion of the Study Area The southern portion of the Study Area includes routes north and south of Wichita, Kansas, north of Springfield, Missouri, and south of St. Louis. Constraints in the southern portion of the Study Area include: Wichita and its associated suburban areas, the extensive airfields in and around Wichita, the Tallgrass Heartland, the expansive Harry S. Truman reservoir, Lake of the Ozarks, Pomme De Terre, Stockton Lake, Mark Twain National Forest, and land administered by the Department of Defense and the National Park Service. Conceptual Routes exiting the western converter station primarily followed either section lines through farm lands east of Wichita, and/or paralleled existing transmission lines north and south of the Wichita metropolitan area. Routing opportunities near Wichita were highly encumbered by the expansive suburbs both north and south of the city, as well as an abundance of airfields associated with Wichita s extensive aviation industry. These two factors led to routes that were developed either north along existing 345 kv lines that crossed midway between Wichita and Newton or south of the city along section/parcel boundaries 10 and 20 miles south of the city. As a result, Conceptual Routes were developed along each of the four 345 kv transmission lines east of Wichita that transect the Tallgrass Heartlands in this area (see Figure 4-4). Beyond the Tallgrass Heartlands, Conceptual Route alignments continued along

56 existing transmission lines or section/parcel boundaries. Although route development through this area was comparatively simple given the low number of residences and public lands, significant oil and gas development sites and numerous wind farms hindered route development in some areas. The Conceptual Routes in southeastern Missouri were primarily developed along roads, section/parcel lines, and paralleling existing transmission lines. Land use in southwestern Missouri is similar to that in eastern Kansas with farms and grasslands primarily used for grazing. The prevalence of grassland areas was specifically noted by MDC as a focus for preservation of grassland/prairie habitat and reintroduction of greater prairie chickens in the area. The Routing Team attempted to avoid these areas and/or parallel existing transmission lines where possible through this area. Continuing east, terrain becomes more variable with less land suitable for agricultural use and a greater proportion of land under forest cover. An increase in large parcels of publicly owned lands, recreational areas, and reservoirs coincides with this physiographic change and greatly affected Conceptual Route development. Most notably, the irregular sprawl of the extensive Harry S. Truman Lake of the Ozarks, Pomme De Terre, and Stockton Lake reservoirs significantly limited the potential for reasonable alignments south of Jefferson City and north of Springfield. Through this area, the most suitable alignments were either along the northern edge of the Harry S. Truman and Lake of the Ozarks reservoirs; weaving south of the Harry S. Truman and Lake of the Ozarks reservoirs and north of Stockton Lake and Pomme De Terre; or following a southern path along an existing 345 kv transmission line between Springfield, Missouri, and Stockton Lake. Farther east, the large land holdings of the Mark Twain National Forest and interspersed holdings of the Department of Defense, National Park Service, and State of Missouri affected Conceptual Route development. Routes developed through this area primarily followed alignments that diverted either north of the main body of the Mark Twain National Forest (Houston/Rolla and Salem/Potosi Ranger Districts) or south along a trajectory between the National Forest System lands and the Ozark National Scenic Riverway. An alignment was also considered that loosely paralleled the north side of I-40 (along a lower voltage transmission line) for more than 150 miles. Direct parallel along I-40 was avoided because of the significant residential and commercial development along the path of the interstate and its role as part of the Historic Route 66 corridor. Remnants of this historic travel way through the Ozarks are found just off I-40 and have been designated as scenic roads by the State of Missouri.

57 Figure 4-4. Conceptual Route Development in the Southern Portion of the Study Area

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59 The extensive network of public lands west of the St. Francois County, Missouri, area guided and limited route development. Conceptual Routes through this area were forced to either: 1) follow along a northern trajectory, ultimately turning south once west of the Potosi Ranger District of the Mark Twain National Forest; or 2) follow a path from the southwest after weaving through the patchwork of state parks and National Forest System lands (between the Salem and Fredericktown Ranger Districts) forming the Heart of the Ozarks recreational attractions. While the extensive network of public lands in the area limited route development opportunities in many places, it also had a compounding effect of concentrating route development to the areas in between the public lands. This effect was encountered throughout the Ozarks region, most notably in the area immediately adjacent to the St. Francois Substation. In this area, several large state parks (the St. Joe and St. Francois State Parks) and a dense stretch of intervening development (Farmington, Leadington, Park Hills, Deslodge, and Bonne Terre) served as major constraints to identifying suitable routes into the St. Francois area. Conceptual Routes east of the St. Francois area were largely guided by the identification of suitable Mississippi River crossing locations. The Routing Team focused on the area south of St. Louis and north of the Shawnee National Forest that occupies the east shore of the river from Grand Tower, Illinois, to roughly the Kentucky border. Few existing utility crossings of the river were found in this area, and extensive development extending south of St. Louis combined with large federal and state conservation areas largely associated with the Mark Twain National Wildlife Complex made many crossing locations unsuitable. The Routing Team considered crossings near Barnhart, along the northern edge of the Mark Twain National Wildlife Refuge; north of the Rush Island Power Plant adjacent to the recently constructed 345 kv line crossing; near Chester, Illinois, at the crossing of Missouri State Route 51; and farther south near Grand Tower, Illinois. Each of these crossings was either highly encumbered by nearby development (Barnhart and Chester crossings) or a combination of state and federal conservation lands (the Shawnee National Forest lands near Grand Tower and the Mark Twain National Wildlife Refuge Complex near Rush Island). In Illinois, the network of Conceptual Routes south of St. Louis continued east and northeast toward the eastern converter station, generally east of the suburbs of St. Louis and Carlyle Lake. Three major Conceptual Routes were developed from the Mississippi River crossing to the Sullivan Substation, with additional route links developed to connect sections of the three Conceptual Routes or to avoid highly constrained areas. Two of these major Conceptual Routes followed a series of existing transmission lines across the state. The first route followed the existing 345 kv lines from Rush Island to Baldwin, West Mt. Vernon, Louisville, Newton, Casey, and into the Sullivan Substation. The second route followed a more southerly path along a mixture of 345 kv and 138 kv lines from Grand Tower to West Frankfort, Norris City, Albion, Olney, Lawrenceville, Hutsonville, and into the Sullivan Substation in Indiana. The

60 third Conceptual Route followed a pipeline from southwest of Steelville, Illinois, and continued northeast past Oakdale, Nashville, and Centralia before turning east at Kinmundy and joining the first Conceptual Route near Louisville, Illinois. In general, the density of residential and commercial development in Illinois was highest near East St. Louis, in the suburbs extending east of the city toward Belleville, and along the I-70 and U.S. Highway 40 corridor. 3 Residential development near Centralia, Mt. Vernon, and West Frankfort also encumbered route development, forcing the development of several new routes that only loosely parallel existing infrastructure or section/ parcel boundaries. Overall, residential density was highest in Illinois in the central and southern portions of the Study Area and lowest in the northern portion of the Study Area. Significant state and federal land ownership and conservation easements along the Mississippi River south of St. Louis, steep bluffs particularly on the Missouri side of the river, as well as residential development along the I-55 corridor led to challenges in identifying suitable river crossing locations Comparison of Conceptual Routes in the Study Area Once the network of Conceptual Routes for the entire Study Area was developed, the Routing Team conducted a comparative review of the Conceptual Routes. The analysis considered the likelihood for potential impacts from the Project through comparisons of key environmental, land use, and engineering factors for a given route or route segment. Initially, comparisons were conducted at the individual Conceptual Route or route segment level to eliminate routes that were likely not suitable as a result of new insight derived from ongoing public and agency coordination efforts, newly acquired data sources, or route reconnaissance efforts. Similar to a fatal flaws analysis, this effort removed those Conceptual Routes that were not likely to reasonably meet the routing guidelines, or simply resulted in likely impacts that were inconsistent with the majority of other routes considered. Several of these removals were referenced in the preceding sections. The Routing Team then compared the overall feasibility of siting the Project in either the northern, central, or southern portion of the Study Area based on major differences between groups of Conceptual Routes in each portion. These analyses identified the broad scale challenges and limitations of each portion of the Study Area and ultimately led to the selection of the portion of the Study Area that the Routing Team would continue to pursue by developing Potential Routes. 3 Like the remnants of Historic Route 66 found along I-40 in Missouri, historic features of the Historic National Road created in 1806 by legislation signed by President Thomas Jefferson are found along the I-70/U.S. 40 corridor. This corridor is listed as a National Scenic Byway by the U.S. Department of Transportation, Federal Highway Administration.

61 Residential density was one of the most notable differences between the northern, central, and southern portions of the Study Area. Given the importance of avoiding residences in the siting process, residential density was a key factor in the comparison. During the development of Conceptual Routes, the Routing Team recognized significant differences in the density of residential development among the northern, central, and southern areas and its effect on developing reasonable alignments along existing transmission lines and pipelines and allowing for relatively straight alignments along section/parcel boundaries. At the four-state scale, digitizing individual residences was not practical, so the Routing Team used census information to provide numerical evidence to support the challenges it observed during development of the Conceptual Routes. The 2010 census data include an estimate of the number of residences within each census block, allowing the Routing Team to derive a residential density (residences/square mile). The results of this analysis, with an overlay of the three generalized portions of the Study Area, are presented in Figure 4-5. To provide the color categorization for the density ranges, the Routing Team evaluated the difficulty of developing routes in areas with varying numbers of residences per square mile. This was accomplished by sampling Public Land Survey System sections (each roughly 1 square mile) throughout the Study Area, assessing the overall difficulty of routing a transmission line through each section, and then counting the number of houses to derive a residential density. As shown on Figure 4-5, the Conceptual Routes through the central portion of the Study Area in Missouri, although generally shorter, would affect areas with significantly greater residential density. Areas of higher residential density begin south of Kansas City and continue to Sedalia, Columbia, Jefferson City, St. Peters, and the metropolitan area north of St. Louis. Moreover, where low residential density areas appear in the central portion of the Study Area south of Kansas City, reservoirs and conservation areas occupy key areas. In addition to high residential densities, the Conceptual Routes in the central portion of the Study Area also had fewer miles parallel to existing transmission lines or pipelines; fewer suitable crossings of the Missouri River that did not impact either federal, state, or private conservation lands; and no suitable locations for crossing the Mississippi River without diverting north to reach crossings in the northern portion of the Study Area all of these increased the overall length of the route. For these reasons, the Routing Team removed the Conceptual Routes in the central portion of the Study Area from further consideration and did not hold Roundtables in those areas. Conceptual Routes in the southern portion of the Study Area also had higher residential densities in Missouri and Illinois than in the northern portion of the Study Area in those two states. Residential density north of Springfield, Missouri, along I-44 (Lebanon and Rolla), and into the St. Francois Substation near Farmington made Conceptual Route development difficult. In addition, the extensive and irregular sprawl of the Harry S. Truman, Lake of the Ozarks, Pomme De Terre, and Stockton Lake reservoirs significantly limited the potential for reasonable alignments. The presence of the Mark Twain National Forest, Shawnee National

62 Forest, U.S. Army s Fort Leonard Wood, National Park Service s Ozark National Scenic Riverway, and extensive state and private conservation lands in the southern portion of the Study Area further constrained the development of reasonable Conceptual Routes. Discussion with MDC and USFWS revealed the southern portion of the Study Area to be least suited for Conceptual Route development because of the amount of land already protected for sensitive species and habitats. Despite these notable challenges in the southern portion of the Study Area, the Routing Team considered the southern portion more reasonable than the central portion of the Study Area and held a series of Roundtables in southern Illinois to add to data gathered at Roundtables held in southern Kansas and Missouri. However, additional routing challenges were identified during meetings with community leaders and regulatory agency representatives in Illinois, and based on further review and consideration of the few suitable Mississippi River crossings south of St. Louis and challenges discussed above in approaching the river from both directions, the Conceptual Routes in the southern portion of the Study Area were also removed from further consideration. Ultimately, the Routing Team considered the Conceptual Routes in the northern portion of the Study Area to be the most suitable for the Project, and the Routing Team focused its route development efforts there. As shown on Figure 4-5, Conceptual Routes through the northern portion of the Study Area fall largely within areas with low overall residential density for the majority of the route. In addition, although public lands and reservoirs are common in the northern portion of the Study Area, they tend to be smaller and more dispersed, preventing the concentration of residential development in the lands between them, and generally providing multiple routing options to consider through an area. At the same time, sensitive habitats are generally limited in northern Missouri and Illinois, and those that are present are either largely avoidable or would result in impacts that could be minimized or mitigated. Lastly, an array of opportunity features of different types are available for the development and refinement of Potential Routes, and multiple suitable river crossing locations were identified for each of the major river crossings.

63 Figure 4-5. U.S. Census Residential Density in the Four State Study Area

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65 4.3 Potential Routes Once the Routing Team focused on the northern portion of the Study Area, the Study Area was effectively reduced for the continued siting activities for the Project and additional route revisions. Because of the multi-state nature of the Project, Alternative Routes were developed and analyzed in Kansas first to determine the Proposed Route (detailed in the Kansas Route Selection Study, 2013). Once the Kansas Proposed Route was selected, Potential Routes in Missouri were refined based on the known location of the Missouri River crossing (detailed in the Missouri Route Selection Study, 2014). The Missouri Route Selection Study, in turn, included the analysis conducted to identify the Mississippi River crossing location, and the starting point of the Potential Routes in Illinois. The results of the Mississippi River crossing analysis and the development of Potential Routes in Illinois are described below Identification of the Mississippi River Crossing Location Many Mississippi River crossings were considered during the Conceptual Route phase. Initial siting efforts focused on locations along the river with existing infrastructure crossings. However, those few sites that were identified with existing infrastructure crossings were either encumbered by residential and commercial development, existing infrastructure, sensitive cultural and recreational resources, or environmentally sensitive federal lands. Thus, the Routing Team also considered an array of crossing locations where no existing infrastructure currently crosses the river. For these crossings, the team considered a variety of factors, including (but not limited to): potential for impacts on public land resources, existing irrigation infrastructure, sensitive species habitats, historic resources, as well as the technical design requirements of the crossing itself. Many potential Mississippi River crossings were considered throughout the routing process. Those that were removed from consideration early in the process were typically: connected to Conceptual Routes that were later removed from consideration (see Section 4.2.4, Comparison of Conceptual Routes in the Study Area); did not meet reasonable engineering requirements (reasonable span lengths or geotechnical concerns); or were connected to routes that would result in unreasonable impacts. The Routing Team focused on five from which the preferred crossing location was ultimately selected (Figure 4-6). The northernmost crossing was near Hannibal, Missouri, while the southernmost was just north of Clarksville, Missouri. Several agency meetings were held with Missouri Department of Natural Resources (MDNR), MDC, USFWS, USACE (Rock Island and St. Louis Districts), IDNR, and Missouri State Historic Preservation Office to discuss each river crossing and receive feedback for incorporation into the final decision. A brief description of each river crossing along with the feedback received from the agencies is discussed below.

66 Figure 4-6. Potential Mississippi River Crossings

67 1. Northern Hannibal Crossing (River Miles ): 4 The northernmost river crossing is located approximately 3.5 miles north of Hannibal, Missouri. This location crosses approximately 14,300 feet of floodplain on the Missouri side before crossing the Mississippi River with an approximate span (from bank to bank) of 5,800 feet. On the Illinois side, the Potential Route crosses approximately 16,150 feet of floodplain. The Potential Route crosses McDonald and Schaffer Islands, both of which are administered by USACE, Rock Island District. Land use on either side of the river within the floodplain is agricultural with few residences located near the Potential Route. Outside the floodplain, the topography increases with steep slopes and varying terrain. The agencies identified several potential concerns with this crossing. USFWS raised an increased concern for the Indiana bat (a federally listed endangered species) along all of the northern river crossings (including this crossing and the two crossings north and south of Saverton). Forested lands along the northern crossings have a higher potential occurrence for both winter hibernacula and summer maternity colony presence. In addition, USACE, Rock Island District, noted its ownership of the two islands and stated that these areas are leased to USFWS and the State of Illinois. USACE also noted that crossing Pool 22 may be incompatible with its current designated use as a Natural Area. 2. North Saverton (River Miles ): A second potential river crossing approximately 1 mile north of Saverton was considered. This crossing includes steep slopes and topography in a densely forested area on the Missouri side, but does not include any floodplain area outside of the edge of the river. The approximate span length across the river is 4,000 feet. On the Illinois side, the route crosses approximately 26,450 feet of floodplain. Landownership on the Missouri side of the river is private and the route crosses Camp Oko-Tipi, a non-profit youth camp. USACE, Rock Island District, administers land on the Illinois side of the river and the route crosses an unnamed island. This Potential Route is approximately 2 miles north of the Saverton Lock and Dam, a National Register Historic District (also known as Lock and Dam No. 22). USFWS noted the pool, which forms at the head of the Saverton Lock and Dam, is used by wintering and migratory waterfowl. USACE, Rock Island District, stated that the land administered by USACE is leased to USFWS and the State of Illinois. In this area, the land use designation is Wildlife Management/Reserve Forest, and USACE maintains the timber rights. USFWS also stated that like the northernmost crossing, this Potential Route may have a higher potential occurrence of both Indiana bat winter hibernacula and summer roosting habitats. In addition, several archaeological sites have been 4 Mileage is measured from the intersection of the Ohio and Mississippi Rivers near Cairo, Illinois (USACE 2015a).

68 previously identified on the Missouri side of the river and will require further investigation. 3. South Saverton (River Miles ): The third crossing is approximately 2.5 miles south of the Town of Saverton. Like the North Saverton crossing, this Potential Route goes from steep topography with dense forest cover to crossing 500 feet of floodplain and the Mississippi River. The Potential Route has an approximate span of 3,370 feet across the river and crosses approximately 36,750 feet of floodplain on the Illinois side. Land ownership on both sides of the river is private; however, the Anderson Conservation Area owned by MDC is located just south of the crossing on the Missouri side of the river. The route also crosses land on the Missouri side of the river owned by Knox County Stone Company, which has an active quarry located just north of the route. A structure will be required on Jim Young Island, which would reduce both the overall span length between structures and their required height. USACE, St. Louis District, has jurisdiction over this river crossing (and all crossings farther south), although the Rock Island District maintains jurisdiction over the land on the Illinois side of the river (Sny Island Levee District). USACE, St. Louis District, stated a preference for this crossing location. Similar to the two crossings discussed previously, USFWS noted a higher potential occurrence of both winter hibernacula and summer roosting habitat. In addition, the Saverton Lock and Dam is located approximately 1.5 miles north of the crossing location, and USFWS noted this as a concern for potential impacts to bald eagles. In particular, the USFWS noted concerns related to potential avian collision issues with the transmission line. Due to these potential impacts to bald eagles in the area south of Saverton Lock and Dam, USFWS requested that a crossing north of the Lock and Dam be selected. The crossing location in this area has some flexibility and will require additional engineering prior to determining the exact location. Known archaeological sites on the bluffs of the Missouri side may impact crossing at this location. 4. Louisiana (River Miles ): This river crossing, located approximately 1.25 miles north of the Town of Louisiana, Missouri, is the only crossing that paralleled an existing linear feature across the river (a gas pipeline). The Potential Route crosses very little floodplain on the Missouri side and transitions from steep slopes down to the river. The Potential Route crosses the southern edge of Blackburn Island, parallel to the existing gas pipeline. Once on the Illinois side of the river, the Potential Route crosses 28,000 feet of floodplain. The total span across the river at this location is 3,200 feet. Structures will be placed on Blackburn Island, which would reduce the span length between structures crossing the river and decrease their required height.

69 Both USFWS and MDC stated this particular location is known for the presence of bald eagles as well as numerous migratory birds, and USFWS expressed concern about potential avian impacts. In addition, USACE, St. Louis District, and MDC discouraged the use of this crossing because of public land associated with the Ted Shanks Conservation Area on Blackburn Island. The conservation area is undergoing a largescale environmental restoration project for forests and wetlands, and further impacts on the island are discouraged. It was also noted that bald eagles, herons, and egrets are known to nest on the island. Although this Potential Route parallels an existing gas pipeline, USACE noted that impacts from the transmission line may be greater because permanent vegetation clearing would be required to maintain appropriate electrical clearances. The Town of Louisiana is the most densely populated area of the five crossings and contains a historic downtown that is included in the National Register. In addition to the above considerations, the Missouri Department of Transportation is evaluating whether to rebuild the bridge at Louisiana in its current location or re-locate the bridge. Therefore, potential conflicts may arise if the bridge is relocated close to the Potential Route crossing. 5. Clarksville (River Miles ): The final river crossing that was presented at the Public Meetings is approximately 3 miles north of Clarksville. The topography is steep and rapidly transitions to the river without crossing floodplain area on the Missouri side. The Potential Route crosses over Pharrs Island before reaching the Illinois side of the river and crossing 24,950 feet of floodplain. The crossing in this location spans approximately 7,950 feet of the river and will require a structure(s) on Pharrs Island to decrease the overall span length between structures and their height. Pharrs Island is surrounded by a bullnose that was constructed to increase habitat for waterfowl and fisheries. The island includes suitable habitat for bald eagle nesting and roosting, as well as Indiana bat habitat. It also provides recreational uses for waterfowl hunting, with numerous blinds scattered on the island. In addition to Pharrs Island, a state wildlife management area just south of the crossing location is managed for waterfowl and other migratory birds. Additionally, numerous cultural sites have been identified along this stretch of the Mississippi River and the Missouri SHPO believes more sites may exist along the bluffs on the Missouri side. Once all the information was reviewed, the preferred river crossing location was determined to be the South Saverton crossing between river miles 299 and 300 (Figure 4-7). This crossing location was preferred by USACE, St. Louis District, and had the fewest conflicts associated with current land use of any the crossings. Although USFWS considered this crossing less desirable due to potential for bald eagle impacts, residential development in this location is low with a quarry bordering the north side of the route and the Anderson

70 Figure 4-7. South Saverton Mississippi River Crossing Fi Fi Fi Fi Fi Fi Fi Fi Fi F gu gu gu gu gu gu gu gu gu gu gu gu g re re re re re re re r Sou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou ou o th th th th th th th th th th th th th t Sav av av av av av av av av av av av av av av av av av av av av av av av av av av aver er er er er er er er er er er er erto to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to to ton Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Mi Miss ss ss ss ss ss ss ss ss ss ss ss ss ss ssis is is is is is is is is is is is is is is i i si si si si si si si si si si sipp pp pp pp pp pp pp pp pp pp pp pp ppi Ri Ri Ri Ri Ri Ri Ri Ri Ri Ri Ri Ri Ri Rive ve ve ve ve ve ve ve ver Cr Cr Cr Cr Cr Cr Cr Cr Cros os os os os os os os o i si si si si s ng ng ng ng ng ng ng

71 Conservation Area on the south side. From an engineering perspective, the South Saverton crossing offers flexibility in the exact alignment across the river and will allow a structure to be placed on Jim Young Island to reduce span length and structure height. In addition, this crossing is located south of the Saverton Lock and Dam where the river is narrower, which also will help reduce structure height. Collision with the transmission line may be considered a potential risk for bald eagles as well as other avian species at waterbody crossings such as at the Mississippi River. To plan for and mitigate these concerns, Grain Belt Express will implement an Avian Protection Plan in accordance with the Avian Power Line Interaction Committee guidance to minimize any potential impacts to avian resources Development of the Potential Route Network The identification of the Mississippi River crossing location focused further route network refinements and revisions on the Potential Routes emanating from the crossing point south of Lock and Dam 22. During the summer of 2014, the Routing Team reviewed information gathered at the Roundtables, conducted additional route reconnaissance, gathered input from regulatory agencies, and conducted comparative reviews of route segments with similar starting points and endpoints, as part of the route network refinement process. By November 2014, the Routing Team identified the Potential Route Network suitable for presentation to the general public at Public Meetings in Illinois (Figure 4-8). The Potential Route Network consisted of 74 interconnected route segments, extending from the Mississippi River to the Wabash River. As discussed in Section 3.3.2, the Routing Team presented the Potential Route Network at the December 2014 and February 2015 Public Meetings. At the meetings, members of the Routing Team assisted attendees in locating their property or other features of concern on aerial photography maps showing the array of Potential Routes under consideration. Participants were provided pens and markers and were encouraged to document the location of their houses, places of business, properties of concern, or other sensitive resources on the printed maps. After the Public Meetings, all of the maps were scanned, geo-referenced, and integrated into the GIS database, and comments received via comment card were correlated with landowner addresses.

72 Figure 4-8. Illinois Potential Route Network

73 4.3.3 Revisions to the Potential Route Network Revisions were made to the Potential Routes following Public Meetings in Illinois to respond to comments that were relevant to routing, consider new information from route reconnaissance and agency coordination, and as a result of ongoing reviews of engineering challenges and solutions. Most of these revisions were relatively small (resulting in the adjustment of Potential Routes by approximately 50 feet to about 200 feet); however, several were larger in scale (changes on the order of miles) and warrant specific discussion (see Figure 4-9). The majority of revisions involved modifying the routes to be aligned along true ownership boundaries rather than along parcel lines between tracts owned by the same owner, and to be farther away from residences. 1. Mississippi River Floodplain: The Mississippi River floodplain is dominated by large parcel farms, flood control infrastructure (levees and drainage ways), wetland complexes, pivot irrigation, and sporadic residences. The Routing Team initially identified several Potential Route alignments along parcel boundaries and the existing Ameren 115 kv transmission line through this area, while still minimizing impacts on pivot irrigation and residences. Following the second round of Public Meetings, one of the existing Potential Routes was revised to take into consideration new information concerning center pivot irrigation operations, farming practices, and landowner input. The revised Potential Route largely followed parcel boundaries east of the channelized Hadley Creek drainage, south along 220 th Street, and east along 230 th Avenue, continuing along parcel boundaries east of the Kiser Creek drainage way. The route crosses the Ameren 115 kv line and continues due east into the bluffs to connect with the Potential Route Network just northwest of the intersection of 290 th Street and 225 th Avenue. This route revision was developed in coordination with the landowners in the floodplain to reduce the amount of farms that would be split by the original alignment through this area. The revisions also reduced the total route length of this route within the floodplain. 2. Pike County, southwest of El Dara: The Potential Routes southwest of El Dara presented during the first and second round of Public Meetings paralleled a 138 kv transmission line for 1.8 miles before angling to the southeast. The Potential Routes were revised for a 2.7-mile stretch to continue due east from the parallel segment for 1.5 miles before turning south to follow parcel boundaries for 1.2 miles. This revision was made to avoid potential sensitive cultural resources and minimize the fragmentation of the contiguous forest along the bluffs at this location.

74 Figure 4-9. Illinois Revised Potential Route Network

75 Nearly half of the length of the revised Potential Route runs along existing parcel boundaries, versus none on the original route segment. The revised Potential Route moves farther from three residences, two along 240 th Avenue and the other along 280 th Lane, compared to the original alignment. One residence is closer to the modified revised Potential Route than to the original Potential Route, although there is significant tree screening between the residence and the route to mitigate potential visual impacts on the residence. 3. Pike County, south of Pittsfield: The Potential Routes were revised south of Pittsfield following the first round of Public Meetings. A landowner at the meeting provided information regarding the abandoned status of the county work farm and suggested a revised route along 225 th Avenue. Accounting for the abandoned county work farm (previously identified as a possible residence from aerial imagery), this section of the modified route has one residence within 500 feet versus two residences on the original Potential Route and it follows along parcel boundaries for more than a mile greater length than the original Potential Route. After angling away from 225 th Avenue, the modified Potential Route moves away from following along parcel boundaries on a southeastern trajectory. The original Potential Route turned due south following parcel boundaries (although not always ownership boundaries). It had one residence in proximity, along 205 th Avenue. The modified Potential Route crosses diagonally across several parcels that are divided into smaller fields, areas of pasture, and forested riparian areas. The fragmented nature of those parcels increases the potential for some structures to be aligned along field boundaries, partially avoiding placing structures within actively farmed ground. The overall modified Potential Route is nearly 1 mile shorter in length than the original and it has fewer homes within 500 feet. 4. Greene and Scott Counties, south of Alsey and Manchester: The Potential Routes south of Alsey and Manchester were revised following the first round of Public Meetings, primarily to align the routes along parcel boundaries and to move farther from nine residences along County Line Road between Greene and Scott Counties. The revised Potential Route was moved north 0.25 mile, to the half section line north of County Line Road before turning due south to the east of Murray Road. In addition to moving farther from residences and despite being nearly a mile longer than the original Potential Route, the modified Potential Route follows parcel ownership boundaries for 5.0 miles versus just 1.2 miles of the original Potential Route (52 percent versus 14 percent of the length of the modified and original Potential Routes, respectively).

76 5. Montgomery County, northeast of Farmersville: A 3.9-mile section of the Potential Route Network was modified northeast of Farmersville, where I-55 is crossed. The original Potential Route continued its east-west trajectory across I- 55 for approximately 2.5 miles before angling due south 0.5 mile west of East 6 th Road. The Potential Route came within fewer than 250 feet of one residence. The Potential Route came close to one residence (within fewer than 250 feet). The Potential Route was modified to angle south before reaching I-55, paralleling a rail line and parcel boundary for 1 mile, before turning back to the east and crossing the interstate highway. The modified Potential Route has zero residences within 250 feet (versus one within 250 feet on the original Potential Route) and parallels an additional 1 mile of parcel ownership boundary. 6. Shelby County, west of Stewardson: West of the Village of Stewardson, the Potential Routes follow a half section line for 9.5 miles. Several residences are close to that half section line between the Union Pacific railroad between Holland and Mode, and 2300 East Road. The original Potential Route diverted south for mile, following no parcel boundaries but avoiding the three residences. The modified Potential Route instead angles northeast to the one-quarter section line, following parcel ownership boundaries for a little more than a mile before angling back down to the original half section line. The revised Potential Route crosses less agricultural land, as the area north of the half section line has a greater mix of agriculture and forested land than the area crossed by the original Potential Route. 7. Pike County, northeast of Rockport: East of the Ray Norbut State Fish and Wildlife Area in Pike County, the Potential Route was modified from a due north-south direction to a northwest to southeast trajectory. The revised Potential Route is 21 percent shorter than the original and crosses significantly less forested land, therefore requiring less ROW clearing. The original Potential Route crosses through several large contiguous forested areas, whereas the modified Potential Route passes through a mix of forest and small agricultural fields. In addition to the modified Potential Route creating less new forest fragmentation and being one quarter shorter in length compared to the original Potential Route, the original Potential Route has one residence close to Dutch Creek Road compared to zero residences in proximity to the modified Potential Route. 8. Pike County, west of Nebo: The Potential Route network between Nebo and Pleasant Hill in Pike County was modified following the second round of Public Meetings. The modified Potential Route is more than 10 percent shorter than the original Potential Route. Neither route is located within 500 feet of any residences, and both routes cross through a similar mix of small forest and agricultural fields on variable terrain. The modified Potential Route removes circuity from the Potential

77 Route network, while incorporating landowner feedback for better placement on their property. 9. Pike County, southern Illinois River crossing: At the southernmost Illinois River crossing, the Potential Route Network was revised to the south by between 0.25 and 0.75 mile. The Potential Route was modified to the south for 0.25 mile, parallel but within the southern boundary of the same landowner. The modified Potential Route angles to the southeast to cross the Illinois River south of Wing Island, continuing to the southeast before resuming the original alignment along 1950 Road North. Landowners at the first round of Public Meetings identified a residence as abandoned on 470 th Street close to (<500 feet) the modified Potential Route. The original Potential Route has two 90 degree angles in agricultural land east of the Illinois River. Overall, the modified Potential Route is 20 percent shorter in length, incorporates landowner feedback for better placement on landowner property, and has fewer and less drastic angles, which could result in less impact to agricultural land. 10. Greene County, south of White Hall: South of White Hall, the Potential Route Network was modified 0.25 to 0.5 mile north to follow a greater proportion of parcel ownership boundaries through this heavily agricultural area. The revised Potential Route is along parcel boundaries for 67 percent of its length, compared to just 32 percent for the original Potential Route. The modified Potential Route also moves farther away from a potential historic residence along U.S. Highway Macoupin County, north of Standard City: The Potential Route Network was modified approximately 1.5 miles north, between Nilwood and Standard City. The revised Potential Route is 1.1 miles longer; however, it has a greater percentage of the route along parcel ownership boundaries (65 percent compared to 52 percent of the original Potential Route). As a result of greater residential density north of Standard City along Klaus Road, Enslow Road, and Bloome Road, the original Potential Route had several residences in proximity. The revised Potential Route is farther from Standard City and this residential development. It largely follows parcel boundaries and a portion of Union Pacific railroad between Nilwood and Carlinville. 12. Montgomery County, east of Waggoner: East of I-55, to the east of Waggoner, the Potential Route Network was revised following the first round of Public Meetings. The revised Potential Route is 0.5 mile longer, but it is along parcel boundaries for 57 percent of its length versus only 20 percent of the original Potential Route. Landowner feedback in this heavily farmed region encouraged modifying the original Potential Routes to better align with parcel boundaries where possible. In addition to the

78 increased alignment along ownership boundaries, the revised Potential Route is farther from several homes along Brown Trail. 13. Montgomery County, southeast of Waggoner: Following the second round of Public Meetings, the Potential Route Network was modified southeast of Waggoner to between 0.25 mile and 0.5 mile south of the original Potential Route. The revised Potential Route maintains a perpendicular crossing of I-55, while gaining nearly 2 miles of additional alignment along ownership boundaries as compared to the original Potential Route. The original Potential Route crossed through the center of several 0.5-acre agricultural parcels. In addition, the revised Potential Route has zero residences within 500 feet compared to one residence within 500 feet on the original Potential Route. 14. Montgomery County, southeast of Harvel: The Potential Routes southeast of Harvel were modified south 0.25 mile from the quarter section line to the half section line between the Nokomis Blacktop and North 22 nd Avenue. The revised Potential Route is nearly 70 percent aligned with parcel ownership boundaries in this heavily agricultural area, as compared to 26 percent for the original Potential Route. The original Potential Route is closer to two private airstrips to the north, one of which was identified during the first round of Public Meetings. 15. Montgomery County, Wenonah: The Potential Route Network was revised to avoid negatively affecting mining operations west of Wenonah. For several miles east and west of Wenonah, the Potential Route Network follows the half section line between Nokomis Blacktop and North 22 nd Avenue. The original Potential Route deviates slightly to the north to avoid a residence and farm outbuildings along Taylorville Road, north of Nokomis. There is a large surface mining operation west of Wenonah. Through conversations with local landowners and representatives from the mine at the first and second rounds of Public Meetings, the Potential Routes were modified to deviate farther north to be aligned adjacent to North 22 nd Avenue. Locating the Potential Route adjacent to the roadway would minimize impacts on farmlands and the mining operations that are negotiating a plan to extend the mine to the south of North 22 nd Avenue. 16. Shelby County, south of Tower Hill: South of Tower Hill the Potential Routes were revised to move approximately 0.75 mile south near 900 North Road. The original Potential Route was 0.25 mile north of 900 North Road, relatively close to the many residences. In contrast, the revised Potential Route is on the half section line south of the road for most of its length, along parcel ownership boundaries. The revised Potential Route is slightly shorter in length and follows parcel boundaries for 63 percent of its total length, versus only 32 percent of the original alignment. The original Potential Route passed within 500 feet of the approximate location of the small Liston Cemetery. The exact

79 location of the cemetery could not be verified due to its remote and wooded surroundings. 17. Cumberland County, northeast of Greenup: Following the first and second round of Public Meetings, the Potential Route Network was modified northeast of Greenup, along the crossing of U.S. Highway 40. The Potential Routes approach the area from the west paralleling the Ameren 345 kv Neoga Casey Breed transmission line. The original Potential Route deviated from the parallel alignment west of U.S. Highway 40 to the northeast, before angling east and then back to the southeast to cross the highway. The highway follows the path of the National Historic Road and has several historic sites and markers along its route. Paralleling existing infrastructure is a recognized method to mitigate impacts to historic features, such as scenic or historic roadways. Unlike the original Potential Route, the revised Potential Route remains parallel to the existing transmission line to cross the National Historic Road. The revised Potential Route continues to the east before resuming a parallel alignment along the existing transmission line. Following the second round of Public Meetings, the Potential Route was further revised to avoid affecting administrative buildings for the Lincoln Trail Motorsports complex. Both the original and revised Potential Routes cross the Motosports Park, as does the existing Casey Breed 345 kv transmission line. 18. Clark County, northwest of West Union: Following the first round of Public Meetings, the Potential Routes south of West Union were revised to follow an alignment roughly 0.25 mile south of the existing Ameren Casey Breed 345 kv transmission line before angling northeast toward the proposed converter station location. The original Potential Route in this area was unduly circuitous, going 1.5 miles south of West Union before circling back to the north toward the proposed converter station site. In addition, the area south and east of West Union has many pivot irrigation systems (15) that would need to be considered in design efforts. The above-described revisions result in Potential Routes that are much shorter in length than the original routing options to go south of West Union and provide a more direct Potential Route to the proposed converter station location. The revised Potential Route passes over the edge of one pivot system, largely avoiding the area south and east of West Union where many more center pivot irrigation systems are in place. Compilation of the Alternative Routes During and after the first two rounds of Public Meetings, the Routing Team reviewed the Potential Route Network in detail with respect to a variety of environmental, cultural, and land use factors, public input on area constraints near the Potential Routes, and engineering input.

80 These reviews resulted in the removal of several links of the Potential Route Network to focus analysis and comparison on those links that had lesser overall impact. The Routing Team compiled the remaining links in the refined Potential Route Network into Alternative Routes (Figure 4-10). To accommodate a reasonable comparison between Alternative Routes, the Routing Team divided the routes into Segment 1 (Alternative Routes A and B), Segment 2 (Alternative Routes C G), Segment 3 (Alternative Routes H O), and Segment 4 (Alternative Routes P and Q) (Figure 4-11 and Figure 4-12). Each segment begins and ends at a similar point for all of the Alternative Routes within that segment, which provides for a reasonable comparison between each of the Alternative Routes. From each of the segments, one Alternative Route was ultimately selected, and when the four selected Alternative Routes were connected, the Proposed Route resulted. Segment 1 begins at the Mississippi River crossing and extends roughly 5 miles east into the river bluffs; Segment 2 continues from the Mississippi River bluffs to a point where the network converges just beyond I-55; Segment 3 continues from I-55 to just east of the crossing of I-70/40 near Greenup; and Segment 4 continues from that point to the Indiana state border. A detailed description of the Alternative Routes is provided in Appendix F.

81 Figure Illinois Alternative Routes

82 Figure 4-11 Alternative Routes in Segments 1 and 2

83 Figure Alternative Routes in Segments 3 and 4

84 4.4 Converter Station As discussed in Section 1.4.3, Converter Stations, three converter stations will ultimately be constructed for the Project. The western converter station will take the power generated from the wind farms in southwest Kansas and convert it to DC electricity. The intermediate converter station will be located in Ralls County, Missouri, and convert DC electricity back to AC for delivery into the MISO electric grid. The eastern converter station will be located in Clark County, Illinois, and convert DC electricity back to AC to be transmitted to the Sullivan Substation in Indiana and injected into the PJM electric grid. The general area for the eastern converter site was selected based on a number of factors, including its proximity to the Sullivan Substation, proximity to a major 345 kv line within a reasonable distance of the route alignments under consideration, and the presence of a transportation network that will be suitable for the safe and efficient transport of large converter station equipment. Once the local area was determined, site-specific factors drove the selection effort, such as proximity to the existing 345 kv line, residences, and suitable access roads; a minimum size requirement able to contain 40 and 60 acres of site development; gentle terrain (to limit grading requirements); and the avoidance of construction in the immediate floodplain of the Wabash River. The location identified for the proposed converter station is in Clark County, Illinois, on a 110- acre site roughly 1 mile north of West Union. The site is primarily agricultural and slopes gently from south to north. It is bounded on the north and east by a narrow wooded corridor along Mill Creek. The site has a terrace running northeast across the center of the property. The Casey-Breed 345 kv transmission line crosses the northern portion of the property. The Alternative Routes either approach the converter station location from the west, are sited along the southern side of the Casey-Breed 345 kv transmission line, or approach along a route that enters the converter station from the southwest. The Alternative Routes exit the substation site on the northeast side of the parcel, paralleling either the northern or the southern side of the existing line. Both Alternative Routes provide a reasonable means of access to the converter station.

85 5. Alternative Route Evaluation This chapter describes the key resources in the Study Area in Illinois and provides a comparative analysis of the potential impacts of each Alternative Route on these resources. The analysis relies on a combination of information collected in the field, GIS data sources, supporting documents, stakeholder input, and the knowledge and experience of the Routing Team. Information presented throughout the chapter is based on a centerline for each Alternative Route. 5.1 Natural Environment Impacts Water Resources Water resources in the Study Area fall within the Mississippi River basin. Streams in the western two-thirds of the Study Area drain to the Mississippi River, whereas streams in the east drain to the Ohio River. Moving from west to east, the Study Area crosses the Sny, Lower Illinois, Macoupin, South Fork Sangamon, Shoal, Middle Kaskaskia, Upper Kaskaskia, Little Wabash, Embarras, and Middle Wabash-Busseron Hydrologic Unit Code -8 watersheds. Major river crossings include the Mississippi, Illinois, South Fork Sangamon, Kaskaskia, Little Wabash, Embarras, and Wabash Rivers. The Study Area ends at the Wabash River, which forms the eastern border of the state. Streams are relatively low gradient throughout the Study Area (Woods et al. 2006). Water resources in the Study Area are presented in Figure 5-1. The majority of freshwater lakes in Illinois are human-made, including dammed stream and sidechannel impoundments, strip-mine lakes, borrow pits, and other excavated lakes. Natural lakes in the Study Area typically include oxbow and backwater lakes along major rivers. The majority of wetlands that once occurred in Illinois have been drained and converted to agricultural use (Illinois Environmental Protection Agency 2014a). The Mississippi and Illinois Rivers have formal levee drainage districts. The Sny Island Levee Drainage District along the eastern flood plain of the Mississippi River is the oldest in Illinois, having been officially established in 1880 shortly after the passage of the current Illinois Drainage Law in The Sny Island Levee Drainage District stretches for more than 60 miles and includes approximately 114,000 acres of floodplain bottomlands. The Study Area crosses both the Hillview and the Hartwell Drainage and Levee Districts along the eastern flood plain of the Illinois River. The Hillview and Hartwell leveed areas total more than 13,400 and 9,700 acres, respectively (USACE 2015b).

86 Figure 5-1A. Ecoregions and Hydrology in Segments 1 and 2

87 Figure 5-1B. Ecoregions and Hydrology in Segments 3 and 4

88 Approximately 30 percent of the state population uses groundwater as their primary source of drinking water. Principal aquifers within the Study Area include three types: sand and gravel, shallow bedrock, and deep bedrock. Principal sand and gravel aquifers in the Study Area are associated with the alluvial deposits of the Mississippi and Illinois Rivers and the river valleys of the Kaskaskia, Little Wabash, and Embarras Rivers. Principal shallow bedrock aquifers in the Study Area occur in the west, primarily in Pike, Scott, and Greene Counties. Principal deep bedrock aquifers are also primarily found in the western portions of the Study Area, including Pike, Scott, Greene, Macoupin, Montgomery, and Christian Counties (Illinois Environmental Protection Agency 2014b). Stream water quality has been degraded across the Study Area by ditching and draining, crop and livestock production, sheet erosion from cultivated slopes, and strip mining (Woods et al. 2006). Several streams in the Study Area are listed on the state s 303(d) list that identifies impaired waterbodies that are not currently meeting water quality standards. IDNR maintains a list of Biologically Significant Streams (BSS), which are streams that have a high biotic diversity or integrity rating or score based on data from at least two taxonomic groups (IDNR 2008). Segment I crosses no BSS. In Segment 2, Alternative Routes C, D, and E cross Bay Creek. Three BSS crossings are located in Segment 3 Becks and Ranger Creeks, which all Alternative Routes cross, and the Embarras River, which Alternative Routes I, K, M, and O cross. In Segment 4, Alternative Route P crosses Mill Creek three times along an existing transmission line, and Alternative Route Q crosses it once. General Impacts and Mitigation Measures Surface Waters Direct impacts on hydrologic features are often minimized or avoided by spanning wetlands, rivers, or drainages, when feasible. In the absence of other constraints, engineers typically seek to place structures at high points in topography, inherently resulting in the avoidance of structure placement that impacts water or wetland features in low-lying areas. However, in a few rare instances, such as at crossings of large wetland areas or complexes, a structure may need to be placed within a wetland. In these instances, the area of permanent wetland loss will be limited to the area of the footprint of the structure foundation, typically between acre and acre of permanent impact (average permanent impact acreage for each footing of a four-footed lattice steel structure and for a monopole structure, respectively). At the Mississippi River crossing location, no structures will be placed in the river; however, a structure will be placed on Jim Young Island. Although impacts to the Mississippi River are not anticipated, wetlands may occur on the island and along the riparian margins of the Mississippi River. Grain Belt Express will continue coordination with USACE to obtain and comply with the necessary Clean Water Act (Section 404) permits for potential impacts that may be associated with wetlands located at the crossing, as well as across the Project.

89 Grain Belt Express will implement best management practices during the design, construction, and operational phases to avoid or minimize impacts on wetlands. These practices may include considering designs that limit clearing forests near drainages and in areas of steep topography, using wetland mats to minimize impacts of construction traffic, and avoiding construction activities during seasonally wet periods in certain areas. Other indirect impacts to surface waters, such as impacts to water quality from sedimentation and erosion of surrounding soils, can result from ground-disturbing activities. Typically, sedimentation is easily controlled with proper perimeter controls around the transmission line construction area. Best management practices may include implementation of sediment control measures, such as silt fences, access road drainage management measures, and timely reseeding of disturbed soil areas. Impacts to water quality would be avoided or minimized for all Alternative Routes because Grain Belt Express will coordinate with the Illinois Environmental Protection Agency and obtain and comply with the necessary National Pollution Discharge Elimination System general storm water permit for construction of the Project. Groundwater Generally, transmission line construction does not impact groundwater. In some instances, dewatering may need to occur in areas with a high water table to place foundations in the ground. Dewatering activities required by construction of any of the Alternative Routes, if necessary, will follow best management practices and be covered under the Illinois Environmental Protection Agency National Pollution Discharge Elimination System general storm water permit or under a separate dewatering permit, as appropriate. Alternative Route Comparison For each segment, Alternative Routes were analyzed with respect to the potential for water resource impacts. A table of the number of stream crossings (including streams, rivers, or drainages that can be perennial, seasonal, intermittent, or ephemeral), number of waterbodies (lakes or ponds) crossed, acres of emergent marsh (herbaceous low-growing vegetation) and forested/scrub-shrub wetlands, and length of the 100- or 500-year floodplain crossed is presented for each Alternative Route, as well as a qualitative discussion of the concerns for specific Alternative Routes. Figure 5-1 shows hydrology for all four segments. Segment 1 Excluding the Mississippi River itself, the transmission line will span all streams and waterbodies in Segment 1 without the use of non-standard design requirements, and wetlands will be spanned when feasible. No structures will be placed in the Mississippi River; however, taller structures and longer spans will be required, and it is likely a structure will be placed on Jim Young Island. When a wetland cannot be spanned, a small amount of wetland fill would be required, as discussed above.

90 In general, the two Alternative Routes in Segment 1 are similar from a water resources perspective, with only minor differences in forested/scrub-shrub wetland acreage, stream crossings, and floodplain length (the vast majority of which is farmed) (Table 5-1). The wetland acreage (based upon NWI data) within the ROW of each Alternative Route is overall similar. Although Alternative Route A crosses the least amount of forested/scrub-shrub wetland, impacts on scrub-shrub wetlands are either unlikely or at most minimal to this type of wetland when spanned. Alternative Route B has more length in the floodplain, which normally suggests a greater potential for impacts on wetlands not found in the NWI data. However, in this case, nearly the entire floodplain has been drained for farming due to its highly productive soils, so impacts on unknown water resources are expected to be minimal. Additional mileage, and therefore additional structures in the floodplain, has a potential for greater impacts on floodplain drainage patterns; however, drainage patterns in the Sny Island Levee District are highly modified through the drainage way and levee system and are easily avoidable. In Segment 1, overall, both Alternative Routes would have similar impacts to water resources. Segment 2 Similar to Segment 1, the transmission line will span all streams and waterbodies in Segment 2. However, Alternative Routes C, D, and E all cross approximately 215 streams and waterbodies, including Bay Creek, a BSS, whereas Alternative Routes F and G cross approximately 130 streams and waterbodies (Table 5-1). Alternative Routes C, D, and E cross Bay Creek perpendicularly in an area with very limited riparian forest; therefore, any impacts on Bay Creek from ROW clearing would be negligible. All Alternative Routes in Segment 2 cross the Illinois River, which will be spanned; however, structures may need to be placed in the leveed floodplains. Alternative Routes C, D, and E all cross the Illinois River at a location parallel to existing pipelines. Although Alternative Routes F and G cross significantly fewer streams, they both cross more mapped floodplain than the other Alternative Routes, and are therefore more likely to require structures placed in floodplains, which are regulated under the Illinois Rivers, Lakes, and Streams Act. The majority of the floodplains in the Hillview and Hartwell Drainage and Levee Districts are in active agricultural use, so it is unlikely that structures in the floodplains would impact wetlands. Alternative Routes F and G, as the two Alternative Routes that follow a southern path for their entirety, cross more forest acreage and larger tracts of contiguous forest. Although the NWI data only show a moderate difference in forest/scrubshrub wetlands crossed by these Alternative Routes as opposed to the others, the amount of forest along the southern Alternative Routes in Segment 2 indicates that Alternative Routes F and G would require the clearing of more riparian forest and forested wetlands.

91 Table 5-1. Alternative Routes Water Resource Information Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 Water Resources Category A B C D E F G H I J K L M N O P Q Stream crossings (count) Waterbody crossings (count) Biologically Significant Steam crossings (count) Emergent wetlands 3 within the ROW 4 (acres) <1 <1 Forested and Scrub-shrub wetlands 3 within the ROW 4 (acres) year or 500-year floodplain crossed (miles) U.S. Geological Survey (2014) 2 IDNR (2014) 3 USFWS (2014) 4 ROW is 100 feet on either side of centerline.

92 Although the number of access road stream crossings will not be known until initial engineering and design is completed, in general Alternative Routes, such as C, D, and E, which have more streams in the ROW, may require more access road stream crossings in the form of culverts or temporary bridges. However, no in-water work is expected to occur in Bay Creek, a BSS. All Alternative Routes have similar acreage of wetlands located within the ROW, although Alternative Route G has the greatest acreage at approximately 26 acres, versus Alternative Route C which has approximately 19 acres. Impacts to wetlands in Segment 2 from any of the Alternative Routes are expected to be minimal because wetlands will be spanned wherever feasible, and access roads through wetlands will incorporate best management practices, which could include the use of construction matting or other protection techniques. Overall, in Segment 2, all Alternative Routes would have similar impacts to water resources, with the exception of the potential for larger floodplain, forested wetland, and riparian impacts in Alternative Routes F and G and the potential for more stream impacts as a result of access roads in Alternative Routes C, D, and E. Segment 3 Overall, all the Alternative Routes in Segment 3 cross similar numbers of streams, waterbodies, and acres of wetlands, although Alternative Routes H, I, J, and K cross the South Fork Sangamon River numerous times. All Alternative Routes in Segment 3 cross the navigable Embarras River. The South Fork Sangamon, Kaskaskia, and Little Wabash Rivers are not navigable at the location where the Alternative Routes cross. All streams, rivers, and waterbodies in Segment 3 will be spanned; however, the aerial crossings of navigable waterways will require Section 10 permits from USACE. Three BSS are crossed within Segment 3. Alternative Routes H, I, L, and M all cross Becks Creek perpendicularly in an area of narrow riparian forest between fields. Alternative Routes J, K, N, and O also perpendicularly cross Becks Creek farther to the south, in an area of denser forest. Because both crossings are perpendicular, the stream will be spanned, and no access road culverts will be placed in Becks Creek; therefore, impacts from any of the Alternative Routes would be minimal. The portion of the Embarras River crossed by Alternative Routes I, K, M, and O is a BSS, whereas it is not a BSS where crossed by Alternative Routes H, J, L, and N. The Embarras River would not be affected because the transmission line will span the river, there will be no in-water work associated with access roads, and the area where Alternative Routes I, K, M, and O cross has only scattered forest, so little riparian forest would be removed. The last of the BSS segments crossed in Segment 3 is Ranger Creek, which is crossed by all the Alternative Routes. However, Alternative Routes H, J, L, and N cross the creek in an area with very little riparian forest that is adjacent to a developed motocross park, so those Alternative Routes would have very little impact. Alternative Routes I, K, M, and O cross Ranger Creek perpendicularly in an area of dense forest, so some riparian forest would be cut;

93 however, because the creek will be spanned and there will be no in-water work associated with access roads, impacts to Ranger Creek would be minimal. Alternative Routes J, K, and O cross the most miles of floodplain, and Alternative Routes H and L cross the fewest miles of floodplain (Table 5-1). Floodplains are likely to contain wetlands beyond those that are mapped by NWI; however, wetlands will be spanned wherever feasible. In addition, crossing more miles in floodplains makes it more likely that structures would have to be placed in a floodplain, which is regulated by the Illinois Rivers, Lakes, and Streams Act. Although Alternative Route K has the greatest wetland acreage within the ROW (31 acres) versus Alternative Routes H and L (19 and 20 acres, respectively), wetlands will be spanned wherever feasible and access roads through wetlands will use construction matting or other protection techniques. If wetlands cannot be spanned, structures in wetlands would result in a small amount of fill and would require USACE permits. In the eastern portion of Segment 3, Alternative Routes H, I, L, and M all cross Richland Creek within the Hidden Springs State Forest. These Routes parallel an existing transmission line in this area that essentially parallels Richland Creek. Paralleling Richland Creek, while also paralleling an existing cleared transmission line, would result in the loss of a wide swath of riparian forest along the steep banks of the creek within the State Forest. IDNR noted this concern in its correspondence regarding the crossing following its own field review of the site. Therefore, although the potential impacts to water resources by the Alternative Routes would otherwise be somewhat similar in the western portion of Segment 3, the impacts to the Richland Creek riparian area within Hidden Springs State Forest suggest that Alternative Routes J, K, N, and O would be preferable in this eastern portion of Segment 3. Segment 4 Within Segment 4, both Alternative Routes would have similar impacts to water resources. Both routes span all streams, rivers, and waterbodies, including the navigable Wabash River. Alternative Route P parallels Little and Snyder Creeks for short distances, which would result in the loss of riparian forest; however, Alternative Route Q does the same for a short distance along Mill Creek. Alternative Route P crosses the BSS Mill Creek three times, all in a close to perpendicular fashion. Mill Creek in this area has a narrow riparian forest buffer through agricultural fields. Because Alternative Route P parallels an existing transmission line for its length, the crossings of Mill Creek would result in a wider length of riparian forest cleared than if the ROW was not adjacent to another transmission line. Although Alternative Route P would have some impact on riparian forest adjacent to Mill Creek, Alternative Route Q would as well. Alternative Route Q crosses Mill Creek while paralleling the same transmission line as Alternative Route P and would have similar impacts. In addition, Alternative Route Q parallels Mill Creek for a short distance, which would result in the loss of additional riparian forest.

94 Wetlands in the ROW of both routes are minimal and will likely be spanned, and there is minimal floodplain, indicating that the placement of structures in floodplains likely could be avoided (Table 5-1) Wildlife and Habitat Vegetation and Habitats Illinois was once a complex mixture of forests, woodlands, savannas, wet to dry prairies, marshes, and swamps occurring on a diversity of landforms that vary in degree of relief, dissection, and geologic parent materials. Today, nearly all of the original prairies have been replaced by agriculture with corn, soybeans, and wheat the main crops. Existing native vegetation in Illinois has undergone extensive fragmentation into smaller tracts. Most of the forests have been removed in flatter areas and are now concentrated in areas unsuited to agriculture, such as steep slopes, ravines, and riparian areas. Scattered forest remnants occur as narrow corridors and islands (Woods et al. 2006). Most of the marshes and swamps have been cleared and drained for agriculture (Woods et al. 2006). Grain Belt Express considered the locations of forest vegetation and potential habitat during its siting process. Along the Mississippi River and its major tributaries, broad floodplains and low river terraces that were once bottomland forests, prairies, and marshes, have been cleared and drained and are now devoted mainly to use as croplands. Scattered forest remnants occur as islands and on the inside of levees. Eastern Illinois consists of broad flat to rolling plains and the bluffs and low hills of the Wabash River. Most former prairies are now used as cropland and hayland in addition to livestock production. Forests on the Wabash River bluffs and low hills are still common on steeper slopes and in ravines, while the majority of flatter areas are cultivated for the production of corn, wheat, soybeans, and hay. The area nearest the Wabash River consists of an alluvial plain, most of which has been cleared and drained for agriculture, although some woodlands, marshes, and swamps remain (Woods et al. 2006). Today, approximately 12 percent of Illinois is covered by forests of which only a small percentage are high quality communities such as floodplain forest, upland forest, sand forest, and flatwoods. The majority of the forests in Illinois have been fragmented into small parcels of land, and the species that require large forested tracts to survive have declined. However, these forests provide stopover habitat during migration for Neotropical migratory birds and breeding habitat for summer resident species. Approximately 19 percent of Illinois is grassland habitat, but fewer than 2,600 acres of high quality prairie remain in Illinois. Most of these grasslands are not large enough areas to support sensitive wildlife species. Illinois has lost approximately 90 percent of its wetlands and remaining wetlands are in poor condition due to fragmentation, siltation, altered hydrological conditions, and exotic species (IDNR 2005).

95 Wildlife Illinois natural communities support and provide habitat for a diversity of wildlife species, including: 403 bird species made up of 204 native breeding bird species, 151 migrant/vagrants, and 48 very rare vagrants; 101 native reptile and amphibian species; 68 native mammal species; 187 native fish species; 104 native mussel and clam species; 170 native snail species; and more than 17,000 native insect species. Game species managed for hunting include big and small game animals, furbearing animals, upland game birds, migratory game birds, and waterfowl (INHS 2015a). In addition, Illinois lies within the Mississippi Flyway, one of the four major North American migratory bird corridors. The Mississippi Flyway stretches from the Gulf Coast of Louisiana, Mississippi, and Alabama up through Canada. During early spring and late fall, many bird species migrate between wintering grounds and summer nesting grounds along this Flyway. Remaining forest, woodland, and savanna communities provide nesting, cover, and foraging sites for a variety of wildlife from amphibians and reptiles, birds, small mammals to large mammal species. Riparian forest cover is also important to fishes and other aquatic organisms, while ephemeral pools in forest and woodland are important breeding sites for amphibians. Numerous animal species use the tallgrass prairies, including amphibians and reptiles, particularly where there is a prairie and wooded riparian zone. Numerous bird species use prairies for summer breeding habitat and migration layovers, while fewer use these areas for overwintering (IDNR 2005). Because much of the Study Area has been converted to agricultural land with limited areas of native habitat remaining, Grain Belt Express considered habitat during its siting process. Conservation Lands Conservation lands primarily include lands in the Natural Resources Conservation Service (NRCS) Wetland Reserve Program, lands in the USDA s Conservation Reserve Enhancement Program (CREP), and IDNR s Conservation Opportunity Areas (COAs). The NRCS Wetland Reserve Program is a voluntary program that allows landowners to protect wetlands on their property under conservation easements. These easements are federal easements that can either be permanent or implemented in 30 year terms (USDA NRCS 2013). The CREP program is also a voluntary program in which environmentally sensitive land is removed from production and conservation practices are introduced in exchange for farmers, ranchers, and agricultural land owners receiving an annual rental rate (USDA CREP 2015). The Illinois Comprehensive Wildlife Conservation Plan and Strategy identifies habitat areas that demonstrate the greatest conservation need and potential and establishes specific conservation goals for the enhancement and protection of these sites (IDNR 2005). No federal wildlife sanctuaries, USDA Forest Service lands, or wild and scenic rivers are found within the Study Area.

96 Conservation Opportunity Areas COAs are priority places for implementing conservation actions and comprehensive wildlife conservation by the IDNR and its partners (IDNR 2005). These areas are locations with significant existing or potential wildlife and habitat resources, identified as high importance for conserving Illinois Species in Greatest Need of Conservation Concern. Conservation actions in these areas are necessary for achieving regional and local conservation objectives, and contribute toward statewide goals. The Alternative Routes cross four COAs the Hill Prairie Corridor-North Section COA, Upper Mississippi River COA, Mason County Sands Areas COA; and the Wabash River and Floodplain and Backwaters Ponds COA (IDNR 2015b). The Hill Prairie Corridor-North Section COA is located in west-central Illinois in Pike and Adams Counties with its west edge along the Mississippi River bluffs. This COA s protected lands include Fults Hill Prairie Nature Preserve, Pine Hills Annex Hill Prairie, Piney Creek Ravine Nature Preserve, several privately owned land and water reserves, nature preserves, and natural heritage landmarks. The priority resources include hill prairies and their associated species with the conservation goal to restore, maintain, and protect fragmented hill prairies that exist on these areas by preventing woody encroachment and protecting and proactively managing for the unique flora and fauna native to the blufftop ecosystems. The objectives are to expand the boundaries of the hill prairies and enroll any unprotected hill prairies and critical habitats for endangered/threatened species into long term protection plans. Alternative Routes A, B, C, D, E, F, and G cross the Hill Prairie Corridor-North Section COA. The Upper Mississippi River COA is located in west-central Illinois along the Mississippi River. It includes mussel and fish communities and migratory birds as priority resources. Alternative Routes A and B cross the Upper Mississippi River COA. The Mason County Sand Areas COA includes 4,000 acres of protected lands across eight natural areas and Clear Lakes open water. The natural areas and Clear Lakes are all north-northeast of the Alternative Routes and are not crossed. The priority resources of this COA include sand prairie, sand savanna, ephemeral wetlands, sand-restricted wildlife, and grassland and savanna species. Alternative Routes C, D, and E cross the Mason County Sand Areas COA. The priority resources in the Wabash River and Floodplain and Backwater Ponds COA include free-flowing river, bottomland forest, bottomland ponds, bald cypress communities, cane restoration, successional areas, shallow-water wetlands, mussels, fishes, river cooter (Pseudemys concinna), copperbelly watersnake (Nerodia erythrogaster neglecta), migratory waterfowl, shorebirds, interior least tern (Sterna antillarum athalassos), cerulean warbler (Setophaga cerulean), red-shouldered hawk (Buteo lineatus), brown creeper (Certhia americana), and prothonotary warbler (Protonotaria citrea) (IDNR 2015b). Alternative Routes P and Q cross the Wabash River and Floodplain and Backwater Ponds COA.

97 Illinois Department of Natural Resources Land Alternative Routes H, I, L, and M cross one IDNR land holding, Hidden Springs State Forest, located in east-central Illinois in Shelby County. The state forest is managed as a multiple use area, including timber and resource management and recreation by IDNR. Most of the timber is classified as mature, second growth oak-hickory forest. Numerous springs are scattered throughout the state forest. In addition, Alternative Routes H, I, L, and M all cross Richland Creek within the State Forest. Because these Routes parallel an existing transmission line that crosses Richland Creek numerous times in a short distance, Alternative Routes H, I, L, and M essentially parallel Richland Creek. Paralleling Richland Creek, while also paralleling an existing cleared transmission line, would result in the loss of a wide swath of riparian forest within the State Forest. Illinois Nature Preserves Commission Lands The Alternative Routes do not cross any Illinois Nature Preserve Commission lands (i.e., Nature Preserves, Land and Water Reserves, and Natural Heritage Landmarks). Illinois Natural Areas Inventory Sites The Illinois Natural Areas Inventory (INAI) is a set of information about high-quality natural areas, habitats of endangered species, and other significant natural features. Information from the INAI is used to guide and support land acquisition and protection programs by all levels of government and by private landowners and conservation organizations. The Alternative Routes cross two INAI sites the Embarras and Kaskaskia Rivers. All sites are aquatic sites and because no structures will be placed within them, no impact on the INAI sites is anticipated. Seven INAI sites are located within 0.5 mile of the Alternative Routes, including Brown Branch Hill Prairie, Embarras River, Brewster Hill Prairie, Kiser Creek Hill Prairie, Harmon Cemetery Site, Kaskaskia River, and West Branch. Audubon Important Bird Areas Audubon Important Bird Areas are sites that provide essential habitat for one or more species of birds and must also support one of the following: 1) species of conservation concern (e.g., threatened and endangered species); 2) restricted-ranges species; 3) species that are vulnerable because their populations are concentrated in one general habitat type or biome; or (4) species, or groups of similar species, that are vulnerable because they occur at high densities to their congregatory behavior. None of the Alternative Routes are within 1 mile of an Illinois Audubon Important Bird Area. Table 5-2 provides a comparison of the Conservation Reserve Enhancement Program and IDNR lands and INAI sites along the Alternative Routes.

98 Table 5-2. Conservation Lands Conservation Land Unit of Measure Conservation Reserve Enhancement Program IDNR land 1 Illinois Natural Areas Inventory Sites 2 Conservation Opportunity Areas Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Crossed by ROW count Area crossed by ROW acreage Within 0.5 mile of route count Crossed by ROW count Area crossed by ROW acreage Within 0.5 mile of route count Crossed by ROW count Area crossed by ROW acreage < <1 0 0 Within 0.5 mile of route count Crossed by ROW count Area crossed by ROW acreage Within 0.5 mile of route count IDNR lands data were obtained from IDNR and include all IDNR-owned land. 2 INAI sites data were obtained from the IDNR as part of its Natural Heritage Inventory database.

99 General Impacts and Protection Measures Vegetation and Habitat During construction, trees and other tall-growing vegetation within the ROW will be removed to maintain appropriate clearances for the conductors. Tall-growing vegetation and the associated habitat will be removed from the ROW for the life of the transmission line. Smaller shrub species (less than 10 feet in height) or grasses will be encouraged to grow where compatible (i.e., non-farmed areas). Forest lands within the ROW would therefore be converted to shrubland or grassland communities. In pasture/grassland areas, little vegetation clearing would be required, and permanent impacts would be limited to the foundations of the structures and any areas requiring permanent access roads. After construction, access roads can be re-vegetated with native grasses or agricultural crops. For areas where a road was cut into the landscape, the road can either be reclaimed back to the original grade or the road bed left in place and re-vegetated for future maintenance needs. Whether or not a road is reclaimed will depend on several factors, including landowner negotiations and need to access that particular section of the transmission line in the future. Wildlife Impacts to wildlife would either be short-term or long-term, depending on the type of impact and nature of the species impacted. Short-term impacts may include temporary displacement from an area due to construction-related noise or temporary modifications in habitat. Longterm impacts would occur if the habitat for the species is permanently removed, such as with the conversion of forested habitat to grassland, or less obviously, when the Project introduces a new feature that degrades the overall quality of the habitat for certain species. Any impacts on habitats should be considered with respect to the current status of suitable habitats and the nature of the current wildlife assemblage. Many of the native grasslands and forest, savanna, and woodland habitats in the Study Area have long been cleared and are tilled yearly for farming. Species that are currently associated with these converted habitats are typically tolerant of farming operations. Forest dwelling species located adjacent to agriculture settings are typically either endemic to or tolerant of edge-type habitats. For many of the species now present, additional permanent impacts would be either unlikely or negligible as a result of the construction of the Project, especially when considering the nature of the species present and the ongoing impacts of other area land uses. Although much of the Study Area is a mosaic of agricultural lands and small forested patches, there are some large relatively undisturbed tracts of forest remaining. These areas are prevalent mostly in the area between the Mississippi River and the Illinois River and in riparian forests of larger rivers and streams. Clearing the ROW in large tracts of forest would decrease the size of interior forest habitat and create new edge habitat. Although edge habitat supports

100 a wide diversity and abundance of species, species that require intact interior forest habitats would lose habitat, possibly altering distribution and migration patterns and isolating habitat patches. The Alternative Route that crosses the fewest large tracts of undisturbed forest and/or parallels existing ROWs would minimize impacts to interior-dwelling species. Alignments parallel to existing ROWs typically result in less potential for forest fragmentation effects, since an edge habitat is already present. Although interior habitat patch size may decrease, it would not be bisected and fragmentation would be minimized. Avian collisions with power lines are a recognized concern for transmission line development. Typically, the risk of avian collision is associated with the smaller diameter and less visible shield wire. In areas with high bird use, collision risk can be avoided or minimized by marking the wire to increase visibility. To minimize avian risk and allow the Project to be constructed in high collision risk areas, Grain Belt Express will develop an Avian Protection Plan in accordance with the suggested guidance and best practices identified by the Avian Power Line Interaction Committee, and in compliance with Clean Line s corporate Avian Program, which outlines Clean Line s commitment to avian protection. The Avian Protection Plan will evaluate potential risks to avian species and develop specific measures to avoid, minimize, and mitigate avian collisions with the transmission line. Although vegetation and wildlife habitats have been considered during Project siting to avoid or minimize impacts, the construction of any linear infrastructure project would result in some loss or change of habitat. Grain Belt Express has consulted with and will continue to consult with USFWS and IDNR to establish methods to avoid and minimize potential impacts. Alternative Route Comparisons The potential for each Alternative Route to impact habitats and wildlife can be generally assessed by comparing each Alternative Route with respect to the amount of natural land cover types crossed, such as forested land cover, wetlands, and grassland areas. Additional assessment criteria include the length of each route through grassland/pasture habitats and the length of new transmission line paralleling existing transmission lines and other linear features. Segment 1 Both Alternative Routes in Segment 1 cross though forested bluffs within the first few miles east of the Mississippi River floodplain, which contain less fragmented forests and native habitats. Once outside of the Sny Island Drainage and Levee District, Segment 1 traverses several larger contiguous forested areas. The Alternative Routes are generally similar with respect to total length and acres of wetland and pasture/grasslands crossed; however, Alternative Route B crosses the fewest acres of forested habitat (Table 5-3). Because Alternative Route B crosses the fewest acres of forested habitats, it would likely result in less forest clearing and forest fragmentation in the Mississippi River forested bluffs than Alternative Route A and would therefore have a lesser impact on wildlife and its habitat.

101 Category Table 5-3. Wildlife Habitat within Alternative Routes Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Total Length (miles) Habitat Type (within ROW) Forested (acres) Wetlands (acres) Pasture/grasslands (acres) Parallel with Existing Linear Features Parallel transmission ROW (miles) Parallel road/railroad (miles) 1 USFWS (2014)

102 Segment 2 In Segment 2, the southern Alternative Routes cross the most tracts of contiguous forest, whereas the northern routes cross more agricultural fields. Alternative Routes F and G are the two routes that stay to the south for their entire lengths, and therefore, cross the most forested land and would result in the most forest fragmentation and impacts on forest-dwelling species. The western portions of Alternative Routes F and G also approximately parallel the Mississippi River floodplain, approximately 2 to 3 miles to the east of the levee, staying in the forested bluffs for approximately 20 miles. Conversely, Alternative Route C is the only route in Segment 2 that remains along a northerly route for its entirety. As such, Alternative Route C crosses the least amount of forested habitat (Table 5-3) and crosses mostly smaller patches of forest that are unlikely to support forest-interior dwelling wildlife species. Alternative Route C also crosses the least amount of pasture/grassland habitat, so this route would have the least impact to grassland-dwelling birds. The wildlife habitat assemblage along Alternative Route C is likely already tolerant of edge-habitat; therefore, Alternative Route C would have the least impact on vegetation and wildlife habitat in Segment 2. Segment 3 The Alternative Routes in Segment 3 vary in length from 93.6 miles (Alternative Route H) to 99.8 miles (Alternative Route J) with the amount of forested habitat generally corresponding to overall length (Table 5-3). The shortest Alternative Route (H) crosses the fewest acres of wetlands and forest habitat. Overall, the western portion of Segment 3 is predominantly pasture/grassland or agricultural with only small forested areas, primarily along the riparian buffers of larger streams or rivers. Once reaching Shelby County, the central and eastern portions of Segment 3 are similar, except all the Alternative Routes cross more extensive forested riparian systems, such as along the Kaskaskia, Little Wabash, and Embarras Rivers. Alternative Routes H and L parallel existing transmission lines for more than a third of their lengths, and Alternative Routes J, I, M, and N parallel existing transmission lines for approximately 20 percent of their lengths, whereas Alternative Routes K and O parallel existing transmission lines for less than 3 percent of their lengths. As discussed previously, paralleling existing transmission lines reduces forest fragmentation, so those Alternative Routes with more parallel would have less of an impact interior-dwelling species. However, Alternative Routes H, I, L, and M cross Hidden Springs State Forest and Richland Creek within the State Forest, while paralleling an existing transmission line. In this case, both linear features parallel a stream and its riparian forest instead of crossing it perpendicularly; therefore, the forest would be completely removed along a large length of stream. Because Alternative Routes H, I, L, and M parallel a transmission line while also paralleling approximately 0.4 mile of Richland Creek, constructing these Alternative Routes would result in the loss of riparian forest in this section well beyond the width the existing ROW.

103 Alternative Routes J, K, N, and O avoid the Hidden Springs State Forest and the subsequent impacts to Richland Creek, making them preferable to the other Alternative Routes. Alternative Routes J, K, N, and O also cross the least amount of pasture/grassland habitat, so these routes would have the least impact on grassland birds. The differences between Alternative Routes J, K, N, and O in terms of vegetation and wildlife impacts are negligible; however, because Alternative Routes J and N parallel considerably more existing linear features through forested habitats than Alternative Routes K and O, they would cause less forest fragmentation. Segment 4 The two Alternative Routes within Segment 4 are generally similar with respect to total length and acres of wetlands, forested lands, and pasture/grasslands crossed; however, Alternative Route P parallels an existing transmission line for its entire length (Table 5-3). Because of this, Alternative Route P would have fewer impacts that result in forest fragmentation and would have the least impact on wildlife and its habitat Special Status Species Grain Belt Express coordinated with USFWS, IDNR, and The Nature Conservancy to identify threatened and endangered species or sensitive species that may potentially be affected by the Project. A search of the USFWS, IDNR, and Illinois Natural Heritage Survey (INHS) websites resulted in a list of threatened and endangered and rare wildlife and plant species with known current ranges within the counties where the Alternative Routes occur (USFWS 2015a; IDNR 2015c; INHS 2015b). Table 5-4 presents all federally listed and state-listed species that may occur in the counties crossed by the Alternative Routes. Specific information for the location of known occurrences of federally threatened or endangered species was obtained from the Illinois Natural Heritage Database. In addition, potential impacts to special status species were determined using historical/current county occurrence information and the potential for suitable habitat to occur along the Alternative Routes. Figure 5-2 below illustrates the distribution of special status species located within the Illinois Study Area.

104 Table 5-4. Federal and State Special Status Species Common Name Scientific Name Status 1 Habitat Association Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl Mammals Gray bat Myotis grisescens FE/SE Caves X Northern long-eared Myotis Caves, mines, woodland, forest bat FPE septentrionalis X X X X X X X X X Indiana bat Caves, mines, stream corridors, Myotis sodalis FE/SE X X X X X X X X X riparian forest Franklin s ground Spermophilus Tallgrass prairie, edge habitats squirrel ST X X franklinii Gray/timber wolf Canis lupus FE/ST Forest, prairie X Birds Piping plover Charadrius melodus FE/SE Shelby County during migration X American bittern Botaurus lentiginosus Least bittern Ixobrychus exilis ST SE Freshwater marshes, marshy lake shores, wet meadows, and prairie sloughs Shallow freshwater lakes and marshes Northern harrier Circus cyaneus SE Marsh, grassland, shrubland X Black-crowned nightheron Nycticorax Bottomland forest, marsh SE nyxticorax King rail Rallus elegans SE Marsh X Upland sandpiper Bartramia longicauda Loggerhead shrike Lanius ludovicianus SE SE Prairies, pastureland and hayfields Open agricultural areas interspersed with grassland X X X X X X X X X X Barn owl Tyto alba SE Grassland, marsh, agricultural fields X X X X X

105 Table 5-4. Federal and State Special Status Species Common Name Scientific Name Status 1 Habitat Association Mississippi kite Ictinia mississippiensis Wilson s phalarope Phalaropus tricolor SE Amphibians and Reptiles Jefferson salamander Mudpuppy Illinois chorus frog Smooth softshell Blanding s turtle Kirtland s Snake Ornate box turtle Timber rattlesnake Ambystoma jeffersonianum Necturus maculosus Pseudacris illinoensis Apalone mutica Emydoidea blandingii Clonophis kirtlandi Terrapene ornata Crotalus horridus ST ST ST Mixed bottomland forest, mixed forest, marshes, fallow fields, openings Wetland, wet meadow, upland grassland Upland deciduous forest, ephemeral pools Permanent lakes, ponds, impoundments, streams, and rivers ST Sandy areas on river lowlands X SE SE ST ST ST Large rivers and streams, lakes, impoundments, bogs, sandbars, mudflats Marshes, bogs, fens, prairie wetlands, sedge meadows, shallows lakes, ponds, floodplains, streams, oxbow lakes Wet meadows, open swamp forests, reservoirs, wet vacant urban areas Prairies, pasture, fields, sandhills, and open woodlands Forests, bluffs and rock outcrops, crop fields Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl X X X X X X X X X X X X X X X X X X X

106 Table 5-4. Federal and State Special Status Species Fish Common Name Scientific Name Status 1 Habitat Association Lake Sturgeon Gravel chub Acipenser fulvescens Erimystax x- punctatus Bigeye chub Hybopsis amblops SE Greater redhorse River chub Eastern sand darter Moxostoma valenciennesi Nocomis micropogon Ammocrypta pellucidum SE Mississippi, Rock, and Ohio Rivers and bottoms of large lakes Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl X X ST Rock and Wabash Rivers X Vermilion River and Brouilletts Creek X X X X SE Illinois, Vermilion, and Fox Rivers X SE Little Vermilion River X ST Vermilion, Embarras, and Little Wabash Rivers Harlequin darter Etheostoma histrio SE Embarras and Wabash Rivers X X Pugnose shiner Notropis anogenus SE Lakes, low-gradient streams X River redhorse Moxostoma ST Mississippi River X X carinatum Western sand darter Ammocrypta Mississippi, Kankakee, and SE X X clarum Kaskaskia Rivers Glacial lakes, floodplains lakes, Starhead topminnow Fundulus dispar ST X swamps, marshes Bigeye shiner Tributaries to the Mississippi and Notropis boops SE X Wabash Rivers

107 Table 5-4. Federal and State Special Status Species Common Name Scientific Name Status 1 Habitat Association Invertebrates Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl Spectaclecase Cumberlandia monodonta FE/SE Mississippi River X Sheepnose Plethobasus cyphus FE/SE Kaskaskia River X Fat pocketbook Potamilus capax FE/SE Rivers in Pike County X Higgins eye Lampsilis higginsii FE/SE Shallow areas in large rivers X Rabbitsfoot Quadrula cylindrica FT/SE Wabash River X Snuffbox Epioblasma triquetra FE/SE Small to medium-sized creeks and larger rivers Elephant-ear Elliptio crassidens ST Ohio and Wabash Rivers X X Ebonyshell Fusconaia ebena ST Mississippi River X X Butterfly Ellipsaria lineolata ST Kaskaskia, Rock, Wabash, Ohio and Mississippi Rivers Black sandshell Ligumia recta ST Mississippi River X X Cobweb skipper Hesperia metea ST Ottoe skipper Hesperia ottoe SE Sand dunes, loess-sand prairies, loess hill prairies, barrens Sand prairies, dunes, loess-sand hill prairies X X X X Swamp metalmark Calephelis muticum SE Meadows, marshes, bogs X Regal fritillary Speyeria idalia ST Tallgrass prairie, wet meadow, open habitats, sandy area X X X X

108 Table 5-4. Federal and State Special Status Species Common Name Scientific Name Status 1 Habitat Association Plants Decurrent false aster Boltonia decurrens FT/ST Eastern prairie fringed orchid Blazing star Platanthera leucophaea Liatris scariosa var. nieuwlandii Wet floodplain forest, on lake/wetland borders Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl X X X FT/SE Mesic to wet prairies and meadows X X X X X X X X ST Mesic savannas X X X X American orpine Sedum telephioides ST Sandstone rocky bluffs X Ear-leaved foxglove Tomanthera auriculata Royal catchfly Silene regia SE Tube beardtongue Penstemon tubaeflorus Pale false foxglove Agalinis skinneriana ST ST SE Forest thickets, dry prairies, dry mesic savannas, successional fields Dry prairies, dry upland forests, dry barren savannas Dry to mesic upland forests, dry prairies, dry mesic and mesic savannas, dry to mesic barren savannas, limestone glades Forest thickets, dry sand prairies, savannas, bluffs X X Pink milkwort Polygala incarnata SE Dry sand or gravel prairies, glades X Prairie spiderwort Large ground plum Tradescantia bracteata Astragalus crassicarpus var. trichoc ST SE Dry prairies, dry sandy prairies, developed lands Dry rocky prairies, glades, glacial till prairies, open woods, blufftops X X X X X X X X X X X

109 Table 5-4. Federal and State Special Status Species Common Name Scientific Name Status 1 Habitat Association Bunchflower Eastern blue-eyed grass Melanthium virginicum Sisyrinchium atlanticum Green trillium Trillium viride SE Buffalo clover Trifolium reflexum ST Narrow-leaved green milkweed Blue hearts Spotted coral-root orchid Wild blue larkspur Asclepias stenophylla Buchnera americana Corallorhiza maculata Delphinium carolinianum Heart-leaved plantain Plantago cordata SE Wolf s bluegrass Poa wolfii SE ST Forest thickets, wet prairies, bluffs, agricultural or successional fields Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl X X ST Mesic prairie X X SE ST Mesic upland forests, mesic floodplain forests, mesic prairies, lake borders, glades, non rocky bluffs Dry prairies, dry mesic savannas, lake borders, glades, successional fields Dry upland forest, loess hill prairies, limestone glades and cliffs Mesic prairies, mesic barren savannas, lake/wetland borders, limestone glades ST Mesic to dry upland forests X ST Dry upland forest, dry sand forests, dry sand prairies, dry barren savannas, sandstone and limestone glades, successional fields Wet floodplain forests, seeps and springs, lake borders, creeks Mesic upland forests, rocky cliffs, lake borders X X X X X X X X X

110 Table 5-4. Federal and State Special Status Species Common Name Scientific Name Status 1 Habitat Association Known Current Range Within Study Area County 2 Pk Sc Gr Ma Mo Ch Sh Cu Cl Arrowwood Viburnum molle ST Dry upland forests, rocky bluffs X Dry sand prairies, dry gravel Bent milk vetch Astragalus distortus SE prairies, dry mesic savannas, dry barren savannas, limestone/ X sandstone glades Fibrous-rooted sedge Carex communis ST Violet collinsia Collinsia violacea SE Mesic, dry mesic, and dry upland forests Dry mesic savannas, dry barrens, sandstone glades Source: USFWS (2015a); IDNR (2015c); Heckert and Ebinger (2002); Nyboer et al. (2006); Mankowski (2010); Nyboer and Ebinger (2004) 1 FE= Federally Endangered, FT= Federally Threatened, FPE= Federally Proposed Endangered, FT/SA=Threatened/Similar Appearance, SE=State Endangered, ST=State Threatened X X 2 Counties: Pk=Pike, Sc=Scott, Gr=Greene, Ma=Macoupin, Mo=Montgomery, Ch=Christian, Sh=Shelby, Cu=Cumberland, Cl=Clark

111 Figure 5-2A. Special Status Species Habitat in Segments 1 and 2

112 Figure 5-2B. Special Status Species Habitat in Segments 3 and 4

113 Federal Species According to the USFWS Illinois County Distribution of Federally Listed Threatened, Endangered, Proposed, and Candidate Species list (USFWS 2015a) and the Illinois Natural Heritage Database, Illinois Threatened and Endangered Species by County (IDNR 2015c), two federally threatened plant species, one federally threatened invertebrate species, seven federally endangered species (two mammal, one bird, and four invertebrate species), and one proposed federally endangered species, the northern long-eared bat, are known to occur within the counties crossed by the Alternative Routes (Table 5-4). Additionally, all counties crossed by the Alternative Routes have potential habitat for Indiana bat and northern long-eared bat. Pike County also has potential habitat for the gray bat. Based on the location-specific data from the Illinois Natural Heritage Database, however, only one known location of any federally listed threatened, endangered, proposed, or candidate species or designated critical habitat occurs with the ROW or within 1 mile of any of the Alternative Routes (Table 5-5). No critical habitat for any federally listed species has been designated along any of the Alternative Routes. The following sections describe habitat characteristics for each species. Mammals Gray Bat Gray bats are found in caves within 2 miles of rivers, streams or lakes, where they hibernate and form maternity and nursery colonies, mostly in the Ozarks. In summer, gray bats forage in areas with open water of rivers, streams, lakes, or reservoirs, and most foraging locations are relatively close to the caves (USFWS 2015a). Therefore, it is important to maintain forested corridors or dispersal routes to foraging habitats. Overall, the species is recovering and numbers have increased significantly in many areas (USFWS 2009). Gray bats are known to occur in 11 counties in Illinois in the extreme southern and westcentral parts of the state. The gray bat is known to occur in Pike County, which Alternative Routes A, B, C, D, E, F, and G cross (USFWS 2015a). USFWS has not designated critical habitat for the gray bat; however, gray bat hibernacula were assigned priority numbers based on the number of gray bats they contained. None of the Priority 1, 2, or 3 hibernacula occur within counties that the Alternative Routes cross. However, Pike County contains a Priority 4 hibernaculum, located approximately 7.3 miles from Alternative Route A and approximately 2.4 miles from Alternative Route B. Priority 4 hibernacula are of marginal consequence and require no action (USFWS 1982). Grain Belt Express will implement protection measures, developed in coordination with USFWS and IDNR, to avoid or minimize potential impacts to the gray bat from construction activities.

114 Indiana Bat Indiana bats hibernate in limestone caves or occasionally, in abandoned mines (USFWS 2015a). In spring, reproductive females migrate and form maternity colonies where they bear and raise their young in wooded areas under the exfoliating bark of dead trees greater than 9 inches diameter at breast height and retain large, thick slabs of peeling bark. Habitats in which maternity roosts occur include riparian zones, bottomland and floodplain, wooded wetlands, and upland communities (USFWS 2007). Investigations have found evidence of summer breeding populations in 18 Illinois counties. Males and non-reproductive females typically do not roost in colonies and may stay close to their hibernaculum or migrate to summer habitat. Summer roosts are typically located behind exfoliating bark of large, often dead, trees or snags that are within canopy gaps in forests, in fencelines, or along wooded edges. Indiana bats forage in or along the edges of forested and riparian areas, eating a variety of flying insects found along rivers or lakes and in uplands. Both males and females return to hibernacula in late summer or early fall to mate and enter hibernation (USFWS 2007). Potential habitat for the Indiana bat occurs statewide in Illinois, and known occurrences are reported in Pike and Macoupin Counties, which the Alternative Routes cross (USFWS 2015a). Illinois is included in the Ozark-Central Recovery Unit for the Indiana bat. These recovery units serve to protect both core and peripheral populations. USFWS has not designated Indiana bat critical habitat within counties crossed by the Alternative Routes. All counties crossed by the Alternative Routes have known summer records of Indiana bat (USFWS 2015a). Indiana bat hibernacula were assigned priority numbers based on the number of Indiana bats they contained. None of the Priority 1 through 3 hibernacula occur within counties crossed by the Alternative Routes. However, Pike County contains a Priority 4 hibernaculum, which is located approximately 6.0 miles from Alternative Route A and 7.3 miles from Alternative Route B. Priority 4 hibernacula are defined as least important to recovery and long-term conservation of Indiana bat and typically have current or observed historical populations of fewer than 50 bats. Illinois has 28 recorded maternity colonies of Indiana bat with recorded maternity colonies in Macoupin, Pike, and Scott Counties, which are crossed by the Alternative Routes. These records are based on the presence of reproductively active females and/or juveniles between May 15 and August 15 (USFWS 2007). Threats to the Indiana bat vary during the annual cycle. During hibernation, threats include modifications or disturbance to caves and mines and human disturbance. During summer months, possible threats relate to the loss and degradation of forested habitat. Migration pathways and swarming sites may also be affected by habitat loss and degradation. However, little is known about the migratory habits and habitats of the Indiana bat.

115 Grain Belt Express will implement protection measures, developed in coordination with USFWS and IDNR, to minimize any potential impacts to the Indiana bat from construction activities. Northern Long-eared Bat Northern long-eared bats are found statewide in Illinois, roosting and foraging in deciduous upland and riparian forests and using snag or den trees that are 9 to 36 inches diameter at breast height and that have loose bark during the spring and summer. In autumn, northern long-eared bats swarm in wooded areas surrounding caves and mines where they hibernate (USFWS 2015a). USFWS issued a proposal to list the northern long-eared bat as endangered in October 2013 with an extended public comment period open until January 2, 2014, and reopened the comment period on November 18, 2014, until December 18, On January 15, 2015, USFWS opened a 60-day comment period on a proposed special rule under Section 4(d) of the ESA that will provide the maximum benefit to the species while limiting the regulatory burden on the public. The Section 4(d) rule will apply only in the event that USFWS lists the northern long-eared bat as threatened. Comments were accepted during a 60-day comment period through March 17, 2015 (USFWS 2015b). A final decision on listing the northern long-eared bat was to be made no later than April 2, The primary threat to the northern long-eared bat is white-nose syndrome, a disease that has killed an estimated 5.5 million cave hibernating bats in the United States and Canada. Other threats include destruction, modification, or curtailment of its habitat or range and human-made factors affecting the northern long-eared bat s continued existence. These threats combined with white-nose syndrome heighten the level of risk. USFWS has not designated critical habitat for the northern long-eared bat. The northern long-eared bat utilizes habitat similar to the Indiana bat; therefore, the measures identified to minimize threats to the Indiana bat would also apply to the northern long-eared bat. These habitat conditions, threats, and minimization efforts are discussed above in the section for Indiana bat. Franklin s Ground Squirrel The Franklin s ground squirrel occurs in tallgrass prairie and is often found along the edges between grasslands and woodlands, forest, thickets, and wetlands. The Franklin s ground squirrel is known to occur in Macoupin and Christian Counties, which are crossed by the Alternative Routes (IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the Franklin s ground squirrel occur within the ROW or within 1 mile of any of the Alternative Routes. The Project is not anticipated to affect the Franklin s ground squirrel because the Project would have limited impacts on prairie habitat. Grain Belt Express will coordinate with IDNR regarding potential impacts to Franklin s ground squirrel and will develop protection measures to avoid or minimize those impacts.

116 Gray/Timber Wolf A reclassification of federal protection status for the gray/timber wolf was published in the Federal Register on April 1, This reclassification established three distinct population segments, whereby USFWS Region 3 (which includes Illinois) is entirely within the Eastern Gray Wolf Distinct Population Segment, where all wolves are federally endangered. The Illinois Endangered Species Protection Act states that all species classified as threatened or endangered by USFWS are automatically placed on the state list. No known self-sustaining gray/timber wolf populations have been documented in Illinois since In 2002, a wolf from the Great Lakes pack was shot in Illinois. The gray/timber wolf occurs in forest and prairie habitat and individual wolves have been spotted in Pike County, which is crossed by the Alternative Routes (IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the gray/timber wolf occur within the ROW or within 1 mile of any of the Alternative Routes. Because the gray/timber wolf does not regularly occur in the areas around the Alternative Routes, none of the Alternative Routes are likely to affect the gray/timber wolf. Birds Piping Plover The piping plover is a rare summer migrant in Illinois and a rare resident along Lake Michigan; however, the species is known to occur in Shelby County, which is crossed by the Alternative Routes (USFWS 2015a; IDNR 2015c; Nyboer et al. 2006). Piping plovers nest on sparsely vegetated beaches, cobble pans, and sand spits of glacially formed sand dune ecosystems along the Great Lakes shoreline, and in the winter, piping plovers forage and roost along barrier and mainland beaches, sand, mud, and algal flats, washover passes, salt marshes, and coastal lagoons (USFWS 2003). However, no known occurrences of the piping plover have been documented within the ROW or within 1 mile of any of the Alternative Routes. Furthermore, the piping plover only potentially occurs in Shelby County during its fall and spring migration period. Because the occurrence of piping plover is infrequent in the areas around the Alternative Routes and the Alternative Routes do not cross known piping plover habitat, the Alternative Routes are not expected to affect the piping plover. Invertebrates Spectaclecase Spectaclecase mussels are found in large rivers having riffles and a stable bottom of large rocks or boulders where they live in areas sheltered from the main force of the river current. The species often clusters in firm mud and in sheltered areas, such as beneath rock slabs, between boulders, and under tree roots. They are known to occur in the Mississippi River in Pike County, which the Alternative Routes cross (IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the spectaclecase occur within the ROW or within 1 mile of any of the

117 Alternative Routes. The Mississippi River will be spanned and no structures will be placed in the river; therefore, the Project is not likely to impact the spectaclecase. Sheepnose Sheepnose mussels are currently found in the Mississippi River in Illinois on mud or gravel bottoms at water depths of a few centimeters to 2 meters. Most populations are apparently small and isolated. There are historical records from the Rock, Kaskaskia, Embarras, Sangamon, and Fox Rivers. They were historically known to occur within 1 mile of Alternative Routes H, I, L, and M in the Kaskaskia River in Shelby County, with the last recorded occurrence in 1970 (IDNR 2015c). There are no known occurrences of the sheepnose within the ROW of any of the Alternative Routes. The Kaskaskia River will be spanned and no structures will be placed in the river; therefore, the Project is not likely to impact the sheepnose. Fat Pocketbook The fat pocketbook mussel prefers sand, mud, and fine gravel bottoms of large rivers. It buries itself in these substrates in water ranging in depth from a few inches to 8 feet with only the edge of its shell and its feeding siphons exposed. The fat pocketbook occurs in the lower Wabash River, which the Alternative Routes cross (USFWS 2015a; IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the fat pocketbook have been documented within the ROW or within 1 mile of any of the Alternative Routes. The Wabash River will be spanned and no structures will be placed in the river; therefore, the Project is not likely to impact the fat pocketbook. Higgins Eye The Higgins eye mussel is a freshwater mussel of larger rivers with sand and gravel bottoms where it is usually found in deep water with moderate currents. Higgins eye mussel has been found in parts of the upper Mississippi River. The Higgins eye has been found in the Mississippi River in Pike County, which the Alternative Routes cross (USFWS 2015a; IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the Higgins eye have been documented within the ROW or within 1 mile of any of the Alternative Routes. The Mississippi River will be spanned and no structures will be placed in the river; therefore, the Project is not likely to impact the Higgins eye. Rabbitsfoot The rabbitsfoot is a freshwater mussel found in sand and gravel substrates in areas having currents in 2 to 3 meters of water. The rabbitsfoot is found in the north fork of the Vermilion River in Clark County, which the Alternative Routes cross (USFWS 2015a; IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the rabbitsfoot have been documented within the ROW or within 1 mile of any of the Alternative Routes. The Vermilion

118 River will be spanned and no structures will be placed in the river; therefore, the Project is not likely to impact the rabbitsfoot. Snuffbox Snuffbox mussels are usually found in medium to large rivers where they usually inhabit bottoms composed of sand and coarse gravel, often in riffles in running water. The snuffbox has been found in the Embarras River in Cumberland County, which the Alternative Routes cross (IDNR 2015c; Nyboer et al. 2006). However, no known occurrences of the snuffbox have been documented within the ROW or within 1 mile of any of the Alternative Routes. The Embarras River will be spanned if crossed by the Alternative Routes and no structures will be placed in the river; therefore, the Project is not likely to impact the snuffbox. Plants Decurrent False Aster The decurrent false aster is found on moist, sandy floodplains and prairie wetlands along the Mississippi and Illinois River alluvial floodplain. It relies on periodic flooding to scour away other plants and compete for the same habitat (IDNR 2015c; Heckert and Ebinger 2002). Decurrent false aster is known to occur in Pike, Scott, and Greene Counties, which the Alternative Routes cross (USFWS 2015a); however, it has not been located within the ROW or within 1 mile of any of the Alternative Routes. Much of the Mississippi and Illinois River floodplains are actively farmed with little native habitat remaining. The Project is not anticipated to impact the decurrent false aster because the Project spans wetlands wherever feasible. Eastern Prairie Fringed Orchid The eastern prairie fringed orchid occurs in a wide variety of habitats, from mesic prairie to wetlands such as sedge meadows, marsh edges, even bogs. It requires full sun for optimum growth and flowering and a grassy habitat with little or no woody encroachment (IDNR 2015c; Heckert and Ebinger 2002). The eastern prairie fringed orchid is known to occur in all of the counties that the Alternative Routes cross, except Pike County (USFWS 2015a). However, no known occurrences of the eastern prairie fringed orchid occur within the ROW or within 1 mile of any of the Alternative Routes. The Project could potentially impact the eastern prairie fringed orchid, most notably through construction activities that occur in mesic prairie. Grain Belt Express will coordinate with USFWS and IDNR to identify protection measures to avoid or minimize potential impacts to the eastern prairie fringed orchid from construction activities.

119 State Species Wildlife Seventy-three state-listed threatened and endangered plant and animal species (11 of which are also federally listed and are discussed above) have known ranges within the counties that the Alternative Routes cross (Table 5-4) (USFWS 2015a; IDNR 2015c). Two state-listed endangered species the lake sturgeon and loggerhead shrike are known to occur within the ROW of the Alternative Routes, and 16 state-listed threatened and endangered animal species occur within 1 mile of the Alternative Routes. The loggerhead shrike occurs in the ROW of Alternative Routes H, I, L, and M. The lake sturgeon is known to occur in the Mississippi River, which Alternative Routes A and B cross. Additionally, three mussel species butterfly, elephant-ear, and black sandshell are known to occur within 1 mile of Alternative Routes A and B. The majority of the fish and mussel species are associated with the large rivers or streams and would likely not be impacted by the Project because these waterbodies will be spanned (Nyboer et al. 2006). More detailed information on state-listed wildlife species in the Study Area can be found in Appendix G. Grain Belt Express will coordinate with IDNR to determine the potential for impacts to state-listed species and will develop protection measures to avoid or minimize potential impacts that could result from the Project. Plants Two federally listed threatened plant species occur in counties that the Alternative Routes cross the decurrent false aster and eastern prairie fringed orchid (USFWS 2015a). These species are described in detail above. An additional 13 state listed threatened and 10 state listed endangered plant species are known to occur in counties the Alternative Routes cross; however, none are known to occur within the ROW of any of the Routes (IDNR 2015c; Heckert and Ebinger 2002) (Table 5-4). Grain Belt Express will coordinate with IDNR to determine potential for impacts to state-listed plant species and will develop protection measures to avoid or minimize potential impacts that could result from the Project. Alternative Route Comparison Table 5-5 provides a summary of the impacts to special status species along the Alternative Routes in Illinois, including the amount of Indiana and northern long-eared bat habitat. The Indiana and northern long-eared bat habitat numbers represent the amount of forested habitat along each ROW, which will need to be cleared for Project construction. Grain Belt Express included this calculation because the Indiana bat is a federally listed species and the northern long-eared bat is proposed for listing and both could occur in all counties that the Alternative Routes cross. Segment 1 No known occurrences of federally listed threatened or endangered wildlife, plant, or aquatic species are reported within the ROW or within 1 mile of the Alternative Routes. No

120 designated critical habitat occurs within the counties that the Alternative Routes cross. Both Alternative Routes A and B cross within 10 miles of known Priority 4 gray and Indiana bat hibernacula. Because there are no documented hibernacula within the ROW or within 1 mile of any of the Alternative Routes, the Project would not impact any known gray, Indiana, or northern long-eared bat hibernacula. Similar to any linear infrastructure project, forested habitat will need to be cleared for the ROW and access roads, which could potentially impact Indiana and northern long-eared bat summer roosting habitat. Alternative Route A crosses the most acres of forested areas and would require the most tree removal (Table 5-5 below). Overall, Alternative Route B crosses less forested habitat in its ROW so it would have the least potential impact to bat species. One reported occurrence of a state-listed endangered fish species, the lake sturgeon, occurs within the ROW of Alternative Routes A and B at the crossings of the Mississippi River; however, neither Route would impact the fish because the Project spans the river. Alternative Route A is within 1 mile of three reported occurrences of state-listed threatened and endangered terrestrial plant species, no reported occurrences of state-listed terrestrial wildlife species, and four reported occurrences of aquatic state-listed species. Alternative Route B is within 1 mile of four reported occurrences of terrestrial state-listed threatened and endangered plant species, one reported occurrence of state-listed terrestrial wildlife species, and five reported occurrences of aquatic state-listed species. Habitat for the state-listed threatened timber rattlesnake occurs in Pike County in areas of bluffs and rock outcrops. IDNR indicated during coordination that the timber rattlesnake could occur in the bluffs between the Mississippi and Illinois Rivers and impacts to the rattlesnake in this area were of concern. Alternative Route B crosses fewer areas of unfragmented forest and timber rattlesnake habitat, including approximately 24 percent less forest than Alternative Route A. All the Alternative Routes cross the Mississippi River, which is known habitat for the statelisted lake sturgeon, river redhorse, and the western sand darter fish; the federally listed fat pocketbook, Higgins eye, and spectaclecase mussels; and the state-listed ebonyshell, butterfly, and black sandshell mussels. However, no impacts are anticipated to aquatic species, including fish and mussel species because the Project spans the Mississippi River and other streams and rivers. If access roads are required to cross smaller streams, Grain Belt Express will implement typical best management practices to further avoid or minimize impacts to aquatic habitats and water quality, as discussed in Section 5.1.1, Water Resources. Therefore, no impacts are expected to federally or state-listed listed aquatic species from any of the Alternative Routes in Segment 1.

121 Routing Criterion Measure Known federal threatened and endangered species 1 State threatened and endangered species 1 Plant species occurrences Wildlife species occurrences Aquatic species occurrences Potential habitat of the Indiana and northern long-eared bats 3 Table 5-5. Impacts to Special Status Species within the Alternative Routes Alternative Routes Within ROW (count) Within 1 mile (count) Within ROW (count) Within 1 mile (count) Within ROW (count) Within 1 mile (count) Within ROW (count) Within 1 mile (count) Within ROW (acres) Segment Segment 1 Segment 2 Segment 3 4 A B C D E F G H I J K L M N O P Q Known federal threatened and endangered species data were obtained from IDNR as a part of its Natural Heritage Inventory database. 2 Designated critical habitat information was obtained from the USFWS Federally Endangered, Threatened, Proposed, and Candidate Species Illinois County Distribution list (USFWS 2015a). 3 This includes forested areas within the ROW (acres).

122 Bald eagles are protected by the federal Bald and Golden Eagle Act and the Migratory Bird Treaty Act. Habitat for the bald eagle exists along major rivers and streams, including the Mississippi River (USFWS 2015a) in Segment 1. The USFWS s National Bald Eagle Management Guidelines recommend that disturbances maintain a buffer of at least 660 feet between Project activities and nests (USFWS 2015a). Grain Belt Express will coordinate with USFWS and IDNR to determine whether any bald eagle nests are located within 660 feet of the Mississippi River crossing and will develop an Avian Protection Plan to evaluate potential risks to avian species and develop specific protection measures to avoid and minimize potential impacts to eagles. Implementing an Avian Protection Plan with such measures will enable Grain Belt Express to construct the Project through areas potentially inhabited by eagles. Segment 2 No known occurrences of federally listed threatened or endangered terrestrial or aquatic species or candidate species are reported within the ROW or within 1-mile of any of the Alternative Routes. No designated critical habitat occurs within the counties the Alternative Routes cross. Because no documented gray, Indiana, or northern long-eared bat hibernacula exist within the ROW or within 1 mile of any of the Alternative Routes, the Project is not expected to impact any known gray, Indiana, or northern long-eared bat hibernacula. The removal of forested habitat for ROW and access road clearing, could, however, impact potential Indiana and northern long-eared bat summer roosting habitat. In Segment 2, the southern Alternative Routes cross the most tracts of contiguous forest, whereas the northern routes cross more agricultural fields. All of the Alternative Routes in Segment 2 would require the removal of forested areas within the ROW; however, Alternative Routes F and G follow paths farther south for their entire lengths and, therefore, cross the most forested land. Conversely, Alternative Route C is the only route in Segment 2 that stays along a northerly route for its entirety and, therefore, crosses the least amount of forest in smaller forest patches. Because Alternative Route C would impact the least amount of forested habitat and is the shortest route, it would likely have the least potential to impact the Indiana and northern long-eared bats (see Table 5-5 above). Within Segment 2, there are no state-listed threatened or endangered wildlife, plant, or aquatic species within the ROW of any Alternative Routes and no state-listed aquatic species within 1 mile of any Alternative Route. Alternative Routes C, D, and E are all within 1 mile of known occurrences of the Illinois chorus frog and the loggerhead shrike, while Alternative Routes F and G are within 1 mile of timber rattlesnake. IDNR indicated during coordination that the timber rattlesnake could occur in the bluffs between the Mississippi and Illinois Rivers and impacts to the rattlesnake in this area were of concern. The western portions of Alternative Routes F and G generally parallel the Mississippi River floodplain, approximately 2 to 3 miles to the east of the levee, staying in the forested bluffs for approximately 20 miles, whereas

123 Alternative Route C directly crosses the bluff. As discussed above, Alternative Route C would affect the least amount of forested habitat. Additionally, Alternative Route C is the shortest route and has the least amount of grassland and wetland habitats within the ROW. Therefore, Alternative Route C is expected to have the least impact on state-listed terrestrial wildlife species. The impacts the Alternative Routes would have on state-listed plant species would be similar because all Alternative Routes, except Alternative Route C, cross within 1 mile of three listed plant species. Alternative Route C crosses within 1 mile of two listed plant species. Grain Belt Express will coordinate with IDNR to determine the potential for impacts to state-listed species and develop typical best management practices and protection measures to avoid or minimize potential impacts that could result from the Project. All the Alternative Routes cross the Illinois River, which is known habitat for the state-listed greater redhorse fish and the federally listed fat pocketbook, Higgins eye, and snuffbox mussels; however, there are no known occurrences of any aquatic species within the ROW or 1-mile of any of the Alternative Routes. Transmission line structures will not be placed in any rivers or streams; if access roads need to cross smaller streams, Grain Belt Express will implement typical best management practices to protect water quality and aquatic species from impacts. As discussed above, although not federally or state-listed, the bald eagle is protected. Habitat for the bald eagle exists in Segment 2 for all Alternative Routes, particularly along major rivers and streams such as the Illinois River. Grain Belt Express will coordinate with USFWS and IDNR to determine whether bald eagle nests are located within 660 feet of the Project and will develop an Avian Protection Plan to evaluate potential risks to avian species and develop specific protection measures to avoid and minimize potential impacts to eagles. Implementing an Avian Protection Plan with such measures will enable Grain Belt Express to construct the Project through areas potentially inhabited by eagles. Segment 3 No known occurrences of federally listed threatened or endangered terrestrial or aquatic species are reported within the ROW, and there are no known occurrences of federally listed terrestrial species within 1 mile of the Alternative Routes. One federally listed species, the sheepnose mussel, is historically known to occur within 1 mile of Alternative Routes H, I, L, and M in the Kaskaskia River; however, it has not been located here since Grain Belt Express will span the river, but it does not expect to conduct any in-water work. If access roads need to cross tributaries of the Kaskaskia River, Grain Belt Express will implement typical best management practices to protect water quality and aquatic species from impacts. Therefore, the Project would not affect the sheepnose mussel. No designated critical habitat occurs within the counties the Alternative Routes cross.

124 Because no documented gray, Indiana, or northern long-eared bat hibernacula occur within the ROW or within 1 mile of any of the Alternative Routes, the Project would not impact any known Indiana or northern long-eared bat hibernacula. The removal of forested habitat for ROW and access road clearing, would, however, potentially impact Indiana and northern longeared bat summer roosting habitat. Segments 3 is generally less forested than Segment 2, having smaller patches of forest interspersed with agricultural and pasture land, except along the forested riparian systems of the larger rivers. All of the Alternative Routes in Segment 3 would require the removal of forested areas within the ROW; however, Alternative Route H has the fewest acres of forest within the ROW. As a result, Alternative Route H would likely have the least potential impact to bat habitat (see Table 5-5 above). Within Segment 3, one reported occurrence of a state-listed threatened or endangered terrestrial species, the loggerhead shrike, occurs within the ROW of Alternative Routes H, I, L, and M in Shelby County in open agricultural areas interspersed with grasslands. Although Alternative Routes H, I, L, and M have known occurrences of the loggerhead shrike, the Alternative Routes parallel an existing transmission line through this area. Because loggerhead shrikes prefer open grassland areas with nearby perches, the Project could improve shrike habitat by clearing the ROW of forested habitats. All of the Alternative Routes cross within 1 mile of known occurrences of state-listed barn owl and Blanding s turtle. Alternative Routes J, K, N, and O cross within 1 mile of two other state-listed wildlife species the Kirtland s snake and the ornate box turtle. During coordination, IDNR indicated that the ornate box turtle is susceptible to impacts while in their hibernacula in friable soils. Grain Belt Express will coordinate with IDNR to determine the potential for impacts to state-listed species and will develop typical best management practices and protection measures to avoid or minimize potential impacts that could result from the Project. All the Alternative Routes cross the Kaskaskia, Little Wabash, and Embarras Rivers, which are known habitat for one of more of the following: the state-listed eastern sand darter, harlequin darter, western sand darter, and bigeye shiner fish, as well as the state-listed black sandshell mussel. As stated above, Grain Belt Express will span all rivers and streams, and it does not expect to conduct any in-water work. If access roads need to cross streams, Grain Belt Express will implement typical best management practices to protect water quality and aquatic species from impacts. Therefore, no impacts are anticipated to aquatic species, including fish and mussels. Segment 4 No known occurrences of federally listed threatened or endangered terrestrial or aquatic species are reported within the ROW or within 1 mile of Alternative Routes P and Q. No designated critical habitat occurs within the counties the Alternatives Routes cross. Because no documented gray, Indiana, or northern long-eared bat hibernacula occur within the ROW or within 1 mile of either of the Alternative Routes in Segment 4, neither Alternative Route would

125 impact known Indiana or northern long-eared bat hibernacula. As is the case with any linear infrastructure project, forested habitat will need to be cleared for the ROW and access roads, which could potentially impact Indiana and northern long-eared bat summer roosting habitat. Both Alternative Routes contain about the same amount of forested habitat within the ROW; therefore, both Alternative Routes would impact bat habitat to the same extent. No known areas of state-listed threatened and endangered terrestrial or aquatic wildlife and/or plant species are crossed by the ROW of Alternative Routes P and Q. Alternative Route P is within 1 mile of one reported occurrence of a state-listed plant species and one reported occurrence of the state-listed timber rattlesnake. Alternative Route Q is within 1 mile of one reported occurrence of a state-listed plant species and no terrestrial wildlife species. Neither Alternative Route in Segment 4 is within 1 mile of a state-listed threatened or endangered aquatic species. Both Alternative Routes within Segment 4 would impact state-listed threatened or endangered species to a similar extent. Grain Belt Express will coordinate with IDNR to determine the potential for impacts to state-listed species and will develop typical best management practices and protection measures to avoid or minimize potential impacts that could result from the Project. All the Alternative Routes cross the Wabash River, which is known habitat for the state-listed gravel chub and harlequin darter fish, the federally listed rabbitsfoot and snuffbox mussels, and the state-listed butterfly mussel; however, none of these species are known to occur within 1 mile of either Alternative Route. Because the Project spans the Wabash River, no impacts are anticipated to aquatic species, including fish and mussels. Transmission line structures will not be placed in any rivers or streams; if access roads need to cross smaller streams, Grain Belt Express will implement typical best management practices to protect water quality and aquatic species from impacts Geology and Soils The Study Area within Pike County is located in the Lincoln Hills section of the Ozark Plateaus physiographic province. The majority of the Study Area is located within the Till Plains section of the Central Lowland physiographic province (Illinois State Geological Survey 2015). Illinois has identified and described level IV ecoregions in the state (Woods et al. 2006). Ecoregions are areas of general similarity in ecosystems and take into account physiography, geology, soils, and vegetation. Moving from west to east, the Study Area includes portions of the Upper Mississippi Alluvial Plain, River Hills, Western Dissected Illinoian Till Plain, Illinois/Indiana Prairies, Southern Illinoian Till Plain, Wabash River Bluffs and Low Hills, and Wabash-Ohio Bottomlands ecoregions. Karst regions are located in the western portion of the Study Area, most commonly within the River Hills ecoregion (Figure 5-3).

126 Figure 5-3. Karst Topograpy and Mining Activity

127 Karst topography is characterized as being formed from limestone that readily dissolves in the presence of water; caves and sinkholes are formed by this process and can sometimes be a conduit to groundwater, making these areas environmentally sensitive. Caves and underground streams and rivers in karst areas provide habitat for animals specially adapted to this environment. Special status species, including sensitive bat communities that hibernate and breed in these geological formations are considered in Section The Study Area is divided into five major land resource areas including the Indiana and Ohio Till Plain, Illinois and Iowa Deep Loess and Drift, Central Mississippi Valley Wooded Slopes, Southern Illinois and Indiana Thin Loess and Till Plain, and the Central Claypan Areas (USDA 2006). Major soil resource concerns include erosion via wind and water, and loss of organic matter through poor management practices (USDA 2006). In general, most of the Study Area has been converted to cropland. Extensive parts of the till plain have been tiled, ditched, and tied into the original drainage system to make the land suitable for cropland and settlement (Woods et al. 2006). General Impacts and Mitigation Transmission construction activities such as vegetation clearing, access road construction, grading, and foundation construction can potentially impact soils by disturbing the native structure of the soil, creating areas of higher erosion potential, compaction, and lower soil permeability/fertility. The severity of soil impacts depends on several variables, including vegetation cover, the slope of the land, soil particle size, thickness of the soil profile, depth to a restrictive layer, soil moisture content, and protection measures employed during construction. Unvegetated soil surfaces are more susceptible to erosion and loss of soil productivity. Removing stumps during tree clearing would increase the potential for soil erosion; leaving topsoil exposed increases the potential of loss by wind and water. Best management practices to minimize erosion impacts may include leaving stumps in the ground, covering exposed soil, and reseeding after construction. Prime farmland and/or farmland of statewide importance will be permanently removed from productivity when present at a given structure location. However, these impacts are anticipated to be minimal because only to acre of farmland is removed from production at any structure site (respectively, monopole and lattice tower with multiple footings estimates), with only 4 to 7 structures typically needed per mile. Permanent impacts to soil would be limited to the areas of farmland that have been removed from production at the structure sites. Although additional temporary impacts would occur during construction from soil disturbing activity, normal farming and grazing can continue up to the base of each structure after construction.

128 Prior to construction activities, geotechnical investigations will be conducted to determine the presence of karst topography or caves along the Proposed Route. In the event that caves or karst topography are discovered during these investigations, special engineering considerations will be incorporated into the design and construction of the transmission line. In addition, best management practices will be implemented to minimize any erosion in areas with karst topography and environmental protection measures will be incorporated to avoid and minimize potential impacts to sensitive species associated with karst environments. Alternative Route Comparison As a result of the implementation of mitigation measures similar to those discussed above and the limited footprint of permanent impacts on soil productivity created by the structures themselves, any impacts to soils would likely be minor for all Alternative Routes; therefore, impacts on soil resources do not provide a usable comparison between Alternative Routes. In comparing Alternate Routes in each segment, both the amount of karst topography and inactive mining land and the length of steep slopes (15 to 20 percent and greater than 20 percent) was also used as an indicator of potential soil impacts. As discussed above, karst topography areas contain sensitive environmental resources and could require special engineering considerations. Similarly, steep slopes could increase the risk of soil erosion and will be taken into consideration during engineering and best management practices will be implemented during construction to prevent erosion. Proper engineering methods will be employed to prevent any Inactive mines from resulting in subsidence. Additionally, protection measures will be employed during construction on agricultural lands to avoid or mitigate soil compaction. Grain Belt Express has signed an Agriculture Impact Mitigation Agreement with the Illinois Department of Agriculture that identifies commitments to mitigate soil compaction and damages to crops, irrigation drainage tiles, irrigation systems, and other related impacts. A copy of the Agricultural Impact Mitigation Agreement is provided as an exhibit to the direct testimony of Grain Belt Express witness, Mark Lawlor. Segment 1 Within Segment 1, both Alternative Routes A and B cross the same length of Karst topography (Table 5-6). In general, there are no notable differences between the Alternative Routes with respect to soil resources; however, Alternative Route A crosses more areas with steep slopes. Segment 2 Within Segment 2, Alternative Routes F and G cross a greater length of karst topography and also are the only routes that will include an area with a known sinkhole within the ROW (Table 5-6). Similarly, Alternative Routes F and G also cross 1,000 feet of greater than 20 percent slopes and approximately 4,000 feet more 15 to 20 percent slopes than the other Alternative Routes. Alternative Route C is the only route that crosses more than a tenth of a

129 Resource Category Table 5-6. Alternative Routes Geology and Soils Resources Information Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Karst Topography (miles) Steep Slopes 15%- 20% (feet) 1,160 1,160 5,490 6,010 6,010 9,780 9,780 1,320 1, ,090 1,380 1,520 1,020 1, Steep Slopes >20% (feet) ,180 2,210 2,210 3,560 3, Inactive Mines Crossed (miles)

130 mile of inactive mined land, indicating subsidence can be a concern in these areas on this Alternative Route. Engineering methods and best management practices can address these concerns; however, overall, Alternative Routes F and G would pose greater geologic and soil concerns than the other Alternative Routes in Segment 2. Segment 3 Karst topography does not exist within Segment 3; however, Alternative Routes H, I, L, and M cross approximately twice the amount of greater than 20 percent steep slopes as Alternative Routes J, K, N, and O and 30 to 50 percent more 15 to 20 percent slopes. All of the Alternative Routes in Segment 3 cross some inactive mine land, so subsidence can be a concern; however, Alternative Routes L and M cross the most. Engineering methods and best management practices can address these concerns; however, overall, Alternative Routes H, I, L, and M would pose greater geologic and soil concerns than the other Alternative Routes in Segment 3. Segment 4 Neither karst topography nor inactive mine land exist within Segment 4; however, Alternative Route P crosses more 15 to 20 percent steep slopes than Alternative Route Q. Overall, however, there is no notable difference in either Alternative Route s impact on soil and geology Natural Environment Summary Segment 1 After analyzing and comparing the two Alternative Routes in Segment 1, Alternative Route B would have slightly less impact on the natural environment than Alternative Route A. Both Alternative Routes would have similar impacts on water resources; however, Alternative Route B crosses less forest, which would result in less impact on forest fragmentation, special-status bat species, and potential timber rattlesnake habitat. Alternative Route B also crosses approximately half as much area of steep slopes, so this route would have less impact on soil and erosion. Segment 2 After evaluating the five Alternative Routes in Segment 2, Alternative Route C would have less impact on the natural environment than the other routes. Alternative Route C is slightly shorter than the other Alternative Routes and crosses the least amount of forest and pasture/grassland. Additionally, Alternative Route C is the only route that crosses the Study Area along a northerly route, avoiding the more plentiful tracts of contiguous forest to the south with a more direct route through the forested bluffs. As a result, Alternative Route C would likely impact less special-status bat wildlife species and timber rattlesnake. Alternative

131 Route C, D, and E, however, cross more streams, potentially requiring more access road stream crossings, and cross less area of steep slopes and karst topography. Segment 3 After evaluating the eight Alternative Routes in Segment 3, there is no obvious Alternative Route with the least impact to the natural environment. Alternative Routes J, K, N, and O would impact water resources, wildlife, and special-status species the least because Alternative Routes H, I, L, and M would require the removal of a large area of riparian forest and there is a known occurrence of the state-listed loggerhead shrike within the ROW in the Hidden Springs State Forest. Of Alternative Routes J, K, N, and O, Alternative Routes J and N parallel the most existing linear infrastructure, which would result in the least amount of forest fragmentation. Similarly, Alternative Routes J, K, N, and O have approximately half as many steep slopes as H, I, L, and M; however, those four routes would have similar impacts on geologic resources. Segment 4 Of the two Alternative Routes in Segment 4, Alternative Route P would have the least impact on the natural environment, including forest fragmentation and interior-dwelling wildlife species, because it parallels an existing transmission line for 100 percent of its route. Both Alternative Routes would have similar impacts to water resources, special-status species, and geologic resources. 5.2 Built Environment Impacts Built environment impacts include direct and indirect impacts to developed land use, agricultural land use, recreational and aesthetic resources, and cultural resources. The Routing Team considered a range of factors that relate to existing and future land uses within the Study Area. The Alternative Routes cross nine counties in the State of Illinois, including Christian, Clark, Cumberland, Greene, Macoupin, Montgomery, Pike, Scott, and Shelby. Land use, based on data from the National Land Cover Database, is shown in Figure 5-4 and displays the cultivated land, forest, and pasture distribution throughout the Study Area. The predominant type of land use throughout the Study Area is agricultural and includes farmlands, range or grasslands, and pastures. Land use type was digitized directly from aerial photography within the potential 200- foot ROW for each Alternative Route in Segment 1 and is shown in Table 5-7. The following sections provide a comparative analysis of the potential impacts of the Alternative Routes on the built environment.

132 Figure 5-4A. Land Use in Segments 1 and 2

133 Figure 5-4B. Land Use in Segments 3 and 4

134 Land Use (miles) Table 5-7. Land Use Based on Land Cover Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Length Developed Residential < < Agriculture/ croplands Pasture/ grasslands Forested Land Water/ Wetlands <0.1 <0.1 1 The sum of lengths within each land use may not equal total alternative route length due to rounding. 2 Developed land use primarily consists of roads. A small percentage of industrial land is also included as developed land Developed Land Uses Developed lands include those lands with residential, commercial, and industrial land uses, as well as institutional land use (e.g., schools, places of worship, cemeteries and hospitals). The Routing Team worked to develop routes that minimized impacts on these land uses where possible by avoiding populated areas and their incorporated boundaries and by developing routes that minimized potential impacts to commercial and industrial facilities to the extent possible. As a result, no residences are located within the ROW for any Alternative Routes. Table 5-8 identifies the total distance the Alternative Routes traverse in each county. Populations in the counties crossed by the Project range from more than 49,000 in Macoupin County to slightly more than 5,500 in Scott County (Table 5-9). Overall, counties located within the Study Area decreased in population by about 3 percent between the 2000 to 2010 census years. During the same period the population of State of Illinois increased by more than 3 percent.

135 County (miles) Table 5-8. Counties Crossed by Alternative Routes Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Christian Clark Cumberland Greene Macoupin Montgomery Pike Scott Shelby Table 5-9. Population Trends State of Illinois Change (%) 12,419,293 12,830, % Counties Crossed by Alternative Routes Christian 35,372 34, % Clark 17,008 16, % Cumberland 11,253 11, % Greene 14,761 13, % Macoupin 49,019 47, % Montgomery 30,652 29, % Pike 17,384 16, % Scott 5,537 5, % Shelby 22,893 22, % Much of the population in the Study Area resides in the small and mid-sized communities that are roughly evenly spread across the Study Area. Rural homes make up the remainder of the population, with approximately 10,000 residences within the 2,500-square-mile Study Area (not including residences within incorporated areas), or roughly 4 residences per square mile. In general, the Routing Team attempted to avoid having Alternative Routes pass through or immediately adjacent to the small towns and their incorporated boundaries and to maximize distance from individual homes in the rural countryside to the extent practical. General Impacts and Best Management Practices Impacts to developed land generally would be limited to restricted use and development within the transmission ROW and changes to the viewshed of parcels crossed by or in proximity to

136 the transmission line (viewshed is discussed in Section 5.2.4). Grain Belt Express will obtain an easement that is approximately 150 to 200 feet wide. The property owner will still own the property under the transmission line. However, use of the ROW will be somewhat restricted to ensure the safe and reliable operation of the transmission line. The transmission ROW will be cleared to its full width of tall growing vegetation (taller than 10 feet) or as necessary for the safe and reliable operation of the transmission line. No physical structures (e.g., houses, barns, and garages) could be constructed within the ROW. The Routing Team attempted to minimize impacts to developed land by maximizing the distance between incorporated areas and individual residences to the extent practical. In addition, the Alternative Routes were developed to parallel parcel boundaries whenever possible to avoid bisecting properties. The Routing Team considered paralleling existing linear infrastructure (transmission lines, pipelines and roadways) as opportunities to consolidate public infrastructure and reduce land use fragmentation. In addition to existing linear infrastructure, the grid-based section lines of the public land survey system and the parcel boundaries that further dissect each section (referred to as section/parcel boundaries) also served to guide the development of alignments along logical divisions of ownership. The Routing Team aligned routes along section/parcel boundaries in the absence of, or as an alternative to, parallel alignments along existing linear infrastructure if existing land use would be more affected by the Project otherwise. This was most relevant in farmed areas, where farming operations extend to the edge of a property boundary. All Alternative Routes parallel existing electric transmission lines, rail corridors, roads, or section/parcel boundaries for some portion of their length (see Table 5-10). Alternative Route Comparison Table 5-10 compares the number parcels crossed by each Alternative Route and the distance from the transmission centerline to nearby residences, places of worship, cemeteries, and schools. No schools are located within 1,000 feet of any of the Alternative Routes. Parcel data were obtained from each county and grouped by size. Where continuous parcels are owned by the same landowner, the parcels are counted as a single parcel.

137 Table Developed Land Use Inventory Alternative Routes Metric Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Length (miles) Parallels Transmission 1.8 (14%) (<1%) 0.2 (<1%) 0.2 (<1%) (miles) Parallels Road/ Railroad (miles) (3%) (22%) (3%) (8%) (8%) (6%) (6%) (1%) (2%) (1%) (3%) (2%) (3%) (2%) (4%) - Sited along Parcel (30%) (21%) (49%) (46%) (44%) (40%) (38%) (38%) (49%) (43%) (53%) (36%) (47%) (41%) (51%) - Boundaries (miles) 1 Residences within 250 feet Residences within 500 feet (38%) 17.5 (18%) 20.2 (20%) 2.6 (3%) 35.1 (36%) 17.5 (18%) 20.2 (21%) 2.6 (3%) 11.0 (100%) 3.6 (31%) 2.2 (19%) Places of Worship within 1,000 feet Cemeteries within 1,000 feet Schools within 1,000 feet Quarries crossed (#) Parcels <10 acres (#) Total parcels crossed In many cases, a single landowner owns one or more contiguous parcels. In these cases, the contiguous parcels were counted as a single parcel when calculating the distance sited along parcel boundaries. 2 Distance calculated from centerline of the Alternative Routes.

138 Segment 1 Segment I traverses the Mississippi River floodplain and bluffs with only limited development. As shown in Table 5-11, El Dara and New Canton are the only communities located within 2 miles of Segment 1. Table Communities Located within 2 miles of Alternative Routes in Segment 1 Community Population (2012 Census) Alternative Routes (distance in miles) A B El Dara New Canton The Routing Team worked to avoid these towns and to distance the Alternative Routes from residential development. Alternative Route A is located closer to both towns but follows an existing transmission line for 1.8 miles when passing south of El Dara. Alternative Route B is farther south from the two incorporated areas aligned along local roadways in the floodplain and parcel boundaries in the bluffs. Both Alternative Routes cross within 500 feet of only a few residences. As Alternative Route A parallels the existing transmission line in the bluffs, it traverses within 250 feet of two residences and one potential future home site with a recently built driveway. Alternative Route B does not cross within 250 feet of any residences. In addition, Alternative Route B crosses the fewest number of total parcels and the fewest small parcels (less than 10 acres in size). In general, crossing larger parcels is preferred to crossing smaller parcels because larger parcels can, in general, accommodate the ROW of the transmission line without limiting the use of a larger portion of the overall property. Neither Alternative Route is located within 1,000 feet of known places of worship. One cemetery is located within 1,000 feet of Alternative Route A; however, the Alternative Route does not cross the cemetery property. While both routes are comparable with respect to impacts to developed uses, Alternative Route B avoids crossing within 250 feet of any residences, is located farther from populated areas, and crosses the fewest total parcels and small parcels, likely decreasing the amount of impacted landowners. Segment 2 The western portion of Segment 2 is dominated by forested areas, the Mississippi River and Illinois River bluffs, and the Illinois River floodplain. Land use east of the Illinois River is predominately agricultural with dispersed forested areas located along tributaries of the Illinois River. Segment 2 is more developed compared to Segment 1. However, parcels tend to be

139 greater than 10 acres in size; therefore, the Alternative Routes were able to avoid close proximity to a large number of residences. Table 5-12 identifies communities located within 2 miles of the Alternative Routes. Table Communities Located within 2 miles of Alternative Routes in Segment 2 Community Population (2012 Census) Alternative Routes (distance in miles) C D E F G Alsey El Dara Farmersville Glasgow 141 * * * - - Harvel Hettick Manchester Milton Modesto Nebo Nilwood Pittsfield 4, Pleasant Hill Raymond 1, Scottville Standard City Time Virden 3, Waggoner White Hall 2, * Crossed by Alternative Route The primarily northern routes (Alternative Routes C, D, and E) head due east and cross the Illinois River parallel to an existing pipeline. These routes are generally closer to towns and cities compared to the southern routes (Alternative Routes F and G) and cross within the incorporated boundaries of the Village of Glasgow after diverging from paralleling the pipeline east of the Illinois River. The southern routes increase the distance from some of these communities by paralleling the Mississippi River bluffs to the southeast before turning east and creating a new aerial crossing of the Illinois River. Alternative Routes C, D, and E parallel a very short distance of existing transmission line before crossing the Illinois River. Each of the Alternative Routes is sited along parcel boundaries for more than 30 miles, with Alternative

140 Route C sited on parcel boundaries for the greatest distance (40.5 miles). Each Alternative Route also parallels a short distance of roadways/railways. All five Alternative Routes cross within 250 and 500 feet of a similar number of residences and a similar number of parcels less than 10 acres in size. Although Alternative Route C traverses the greatest number of total parcels, it is more than 2 miles shorter than any other Alternative Route. No places of worship are located within 1,000 feet of the Alternative Routes. Although all of the Alternative Routes are within 1,000 feet of three cemeteries, no cemeteries are physically crossed by any of the Alternative Routes; therefore, impacts are not anticipated. In general, differences between the Alternative Routes in Segment 2 with respect to developed uses are not significant. However, Alternative Route C is slightly shorter than the other Alternative Routes, crosses the Illinois River adjacent to an existing pipeline, has fewer residences within 500 feet, and is sited along parcel boundaries for a greater distance. Segment 3 Segment 3 is predominately agricultural and is the most developed portion of the Study Area. The Routing Team attempted to avoid having any of the Alternative Routes run within any towns, villages, or cities. However, it was not always feasible to avoid crossing the incorporated boundaries of nearby communities (Table 5-13). With the exception of Alternative Routes I and K, each Alternative Route crosses within the boundaries of at least one community. Between I-55 and the City of Pana, all of the Alternative Routes generally run along parcel boundaries. The northern routes in this area (Alternative Routes H, I, J, and K) are generally located farther from communities and require fewer detours to avoid development. The southern routes in this area (Alternative Routes L, M, N, and O) require more detours to avoid development and traverse within the Village of Wenonah adjacent to an active quarry. East of the Pana Substation, there are more opportunities to parallel existing transmission lines. However, residential development is located close to the transmission lines in this area, which makes paralleling less desirable. Between the Pana Substation and the next location where the Segment 3 routes intersect east of I-57, the northern routes in this area (Alternative Routes H, I, L, and M) generally follow a combination of parcel boundaries and existing transmission, while the southern routes in this area (Alternative Routes J, K, N, and O) generally follow along parcel boundaries. The Alternative Routes do not cross any incorporated communities in this area. East of I-57, the northern routes in this area (Alternative Routes H, J, L, and N) parallel an existing transmission line through the Village of Greenup. The southern routes in this area (Alternative Routes I, K, M and O) avoid Greenup by traversing to the south along to parcel boundaries.

141 Table Communities Located within 2 miles of Alternative Routes in Segment 3 Population Alternative Routes Community (2012 Census) H I J K L M N O Casey 2, Coalton Cowden Greenup 1,537 * 0.6 * 0.6 * 0.6 * 0.6 Harvel Jewett Morrisonville 1, Nokomis 2, Oconee Ohlman Pana 5, Raymond 1, Sigel Stewardson Toledo 1, Wenonah * * * * * Crossed by Alternative Route Greater than one-third of Alternative Routes H and L parallel existing transmission lines. As mentioned above, however, many homes are immediately adjacent to or are near the existing lines. As a result, compared to the other Alternative Routes, Alternative Routes H and L cross within 250 and 500 feet of the most residences. Similarly, compared to most other Alternative Routes, Alternative Routes J and N also parallel a significant distance of existing transmission line and are located within 250 feet of more residences. Alternative Routes O and K, which only parallel existing transmission for a short distance, have the fewest residences within 250 and 500 feet. No places of worship are located within 1,000 feet of the Alternative Routes. All of the Alternative Routes are within 1,000 feet of several cemeteries. None of the Alternative Routes cross cemeteries; therefore, impacts are not anticipated. As shown in Table 5-10, Alternative Route K crosses the least number of parcels that are less than 10 acres in size (33); however, all of the remaining Alternative Routes are similar in this respect. Alternative Route K crosses the most total parcels with 674, nearly 70 more than Alternative N with the fewest total parcels crossed (605) but is the only Alternative Route that is sited along parcel boundaries for greater than 50 percent of its total length. Although Alternative Route K is the third longest route in Segment 3, it is expected to result in fewer impacts to developed uses compared to other routes because it avoids crossing the incorporated boundaries of any communities, is sited along parcel boundaries for the greatest distance (53 percent of its route), has the fewest residences located within 250 and 500 feet,

142 and crosses fewer small parcels. Although Alternative Routes H and I are around 4 to 5 miles shorter, they cross within 250 and 500 feet of more residences than the other Alternative Routes. Segment 4 Segment 4 is predominantly agricultural with sparse residential development. The only town in Segment 4 located close to the Alternative Routes is West Union, which is south of both Alternative Routes (Table 5-14). Table Communities Located within 2 miles of Alternative Routes in Segment 4 Community Population (2012 Census) Alternative Routes (distance in miles) West Union P Q Alternative Route P parallels existing transmission for its entire route, while more than half of Alternative Route Q parallels a combination of existing transmission and parcel boundaries. Neither Alternative Route traverses within 250 feet of any residences. Compared to Alternative Route P, Alternative Route Q traverses within 500 feet of three fewer residences but closer to the community of West Union. Alternative Route P crosses within 1,000 feet of a church and a cemetery, while Alternative Route Q does not. However, Alternative Route P does not cross either feature; therefore, impacts are not anticipated. Both Alternative Routes traverse a similar number of total parcels and parcels less than 10 acres in size. While both routes are comparable with respect to developed uses, Alternative Route P is expected to result in fewer impacts to developed uses because it is 0.7 mile shorter than Alternative Route Q, parallels an existing transmission line for 100 percent of its route, and crosses within 500 feet of only a few residences Agricultural Use (Farm and Pasture/Grassland) As previously mentioned, land use within the Study Area is predominately agricultural with the most productive cultivated land in the Mississippi and Illinois Rivers floodplains. The main agricultural crop commodities in Illinois include corn, soybeans, and wheat. Livestock commodities include cattle, goats, sheep and hogs (USDA NASS 2013). Market value of Illinois agricultural products sold was estimated at approximately $17.2 million dollars, ranking seventh within the U.S. market in 2007 (USDA NASS 2013). Pastures are used for grazing cattle and for the production of hay to feed livestock in the winter. Most of the Study Area uses dry land farming techniques, except areas in the Mississippi, Illinois, and Wabash floodplains where

143 center pivot irrigation is common. Extensive networks of drain tile are found in the central part of the Study Area in Macoupin, Montgomery, and Christian Counties. General Impacts and Best Management Practices Impacts to agricultural land (crops and pasture/grassland) would be primarily confined to the construction phase of the Project. In croplands, access into fields during construction may be required during the growing season, which could damage crops or take an area out of production while the transmission line is being constructed. Landowners will be compensated for crop damage as a result of construction of the transmission line. In grassland or pastureland, access across land may be required and could temporarily remove some area from grazing activities during construction. In addition, soil compaction and erosion may be possible, but best management practices will be used to mitigate impacts resulting from soil erosion or compaction. Grain Belt Express has also signed an Agriculture Impact Mitigation Agreement with the Illinois Department of Agriculture that identifies commitments to mitigate soil compaction and damages to crops, irrigation drainage tiles, irrigation systems, and other related impacts. A copy of the Agricultural Impact Mitigation Agreement is provided as an exhibit to the direct testimony of Grain Belt Express witness, Mark Lawlor. The Routing Team attempted to minimize impacts to agricultural land by avoiding center pivot irrigation systems to the extent possible and by siting along parcel boundaries to minimize bisecting agricultural land. None of the Alternative Routes in Segments 1, 2, or 3 cross known center pivots. In Segment 4, eight center pivots are located along the ROW for Alternative Routes P and/or Q. However, the transmission line will be designed to span any area where the ROW overlaps with an irrigation system, thereby avoiding impacts on the operation of the pivot arm. Specific to cropland areas, once the transmission line is constructed, farmers would have to farm around the transmission structures. These impacts are not expected in grassland or pasture areas because large cultivation equipment is not typically used and livestock could move freely under the transmission line. As mentioned previously, the footprint of each structure location would be permanently taken out of cropland production and could no longer be used for grazing (roughly acre for a typical single foundation structure). In accordance with the Agriculture Impact Mitigation Agreement, all tangent structures will use only single, drilled pier type concrete foundations or direct embed type foundations that are typical of single pole type structures. Grain Belt Express will not use multi-foundation lattice type structures for tangent structures, although such structures may be used for turns, long spans such as river crossings, and similar situations where specific engineering and environmental challenges are present. The use of guy wires will be avoided to the extent feasible. If guy wires are required, they will be marked with highly visible guards. To the extent feasible, guy wires and their

144 anchors will be placed out of crop and hayland, and will be placed along existing lines (e.g., property lines; section, quarter, and half section lines; and fence lines) and on land not used for row crops or hay. Generally, livestock grazing operations do not require large machinery for plantings, chemical application, or harvesting, and operational impacts to these facilities would be minimal. Routing transmission lines along parcel boundaries or fence lines is considered the best routing option in cropland areas. Routing on parcel boundaries places the disturbance between ownerships, often minimizing the obstruction on farming operations for each landowner. In contrast, routing a transmission line diagonally through cultivated fields often involves support structures located in the middle of the fields rather than on the edge. This scenario results in a greater impact on farming operations because it creates a new obstacle to farm around. Thus, when possible and practical, the Routing Team placed alignments along parcel boundaries in cultivated areas. This was most practical in areas with large parcels aligned closely to section/parcel boundary lines. Alternative Route Comparison Segment 1 As shown in Table 5-7, most of the length of Alternative Routes A and B crosses agricultural lands. Both Alternative Routes cross a similar distance through agricultural land primarily cropland and avoid crossing any existing center pivot irrigation systems. After crossing the Mississippi River, the first approximately 2.3 miles of Alternative Route B diagonally crosses some irregularly shaped cultivated fields. However, careful structure placement through these fields should minimize potential impacts on agricultural operations. As described in Section 4.3.3, Alternative Route B was developed in coordination with the landowners in the floodplain to minimize the need to place structures in the middle of large contiguously farmed fields with extensive pivot irrigation, and instead place structures alongside roads or between fields that would not be farmed contiguously (due to physical breaks such as drainage channels, elevation changes, or roads). Thus, Alternative Route A and B each would likely have comparatively similar impacts on agricultural operations despite length differences. Segment 2 Each of the Alternative Routes crosses between 53 and 58 acres of agricultural land. None of the Alternative Routes cross existing center pivot irrigation systems. Where the Alternative Routes cross agricultural lands, they typically run along parcel boundaries. Given the similar distance of agricultural lands crossed, the Alternative Routes in Segment 2 are expected to result in similar impacts to agricultural lands.

145 Segment 3 Each Alternative Route crosses approximately 70 acres of agricultural land. None of the Alternative Routes cross existing center pivot irrigation systems. Several of the Alternative Routes in Segment 3 parallel a significant distance of existing transmission lines. However, the existing transmission lines within Segment 3 often pass diagonally through agricultural fields instead of following along the edge of parcel boundaries. Parallel alignments along these lines (Alternative Routes H, I, J, L, M, and N) may likely result in more frequent structures in the middle of a cultivated field, impacting farming operations more than Alternative Routes that primarily run along parcel boundaries (Alternative Routes K and O). Segment 4 Alternative Routes P and Q traverse similar distances through cultivated lands. However, the alignment of Alternative Route P along the north side of the existing transmission line allows impacts on existing pivot irrigation in the Wabash River floodplain to be avoided. In contrast, Alternative Route Q, aligned on the south side of the existing transmission line, would likely limit the operation of one or two existing pivots and require larger spans and taller structures to avoid others. In general, this difference indicates that Alternative P would have a lesser overall impact on agricultural use in Segment Aesthetic Resources The assessment of potential aesthetic impacts commonly includes a characterization of the visual landscape, followed by the identification of visually sensitive areas, and a description of the potential for those visually sensitive areas to be impacted by the Project. The most visually sensitive areas for transmission infrastructure commonly include those areas near historic sites with sensitive viewsheds, major recreation sites that rely on natural scenic views, or areas with dense residential development. Potential impacts on historic resources are presented in Section Illinois hosts a range of natural and cultural-based recreational opportunities, including both dispersed and developed recreational area types. Examples of dispersed recreational activities include scenic driving, bicycling, backpacking, hunting, fishing, and off-road vehicle use. Developed recreation provides permanent facilities designed to accommodate activities such as camping, boat launching, sporting activities in athletic fields, or day-use activities (i.e., picnicking, visiting interpretive exhibits, and hiking/biking on trails). Predominant recreational activities include hunting, observing wildlife, siting tourist attractions, scenic driving, hiking/biking on National Historic Trails, boating activities on the reservoirs and rivers, and camping at state parks. Many of these areas have recreational uses that are driven in part by area aesthetics. Area aesthetics are defined as a mix of landscape visual character, the context in which the landscape

146 is being viewed (view/user groups), and the scenic integrity of the landscape. The potential visibility and visual impact on the landscape and recreational areas from the four segments Segment I through Segment 4 were reviewed through landscape character assessment, field evaluation, and environmental factor tabulations. Description of Visual Character Visual character encompasses the patterns of landform (topography), vegetation, land use, and aquatic resources (i.e., lakes, streams, and wetlands). The visual character of an area is influenced by natural systems, human interactions, and use of land. In natural settings, the visual character attributes are natural elements, such as forested hillsides, open grasslands, or scenic rivers and lakes, whereas rural or pastoral/agricultural settings may include human-made elements such as fences, walls, barns and outbuildings, and occasional residences. In more developed settings, the visual character may include commercial or industrial buildings, manicured lawns, pavement, and other infrastructure. Photographs of the Study Area presented below were taken aerially from a helicopter, so they do not depict the view from the ground. In Segment 1, visual character changes dramatically from west to east. The western part of the segment is characterized by the wide views of flat floodplain farmlands with the bluffs of the Mississippi River visible in the distance to the west (in Missouri) and along the edge of the floodplain to the east. Notable features on the landscape include tilled land and/or row crops, farm equipment, irrigation infrastructure, existing transmission and distribution lines, as well as drainage channels and levees. This view is typical of the floodplain for many miles to both the north and south and can be seen from U.S. 96, which is part of the Great River Road National Scenic trail.

147 Floodplain farmlands of the Mississippi River showing river bluffs in Missouri (facing west) Visual character changes dramatically in the eastern bluffs of the Mississippi River floodplain roughly 7 miles east of the river s edge and continues to the Illinois River. Here, elevation and topographic variability change dramatically, as does the proportion of farmable lands. Views are shortened because hills and heavily forested drainages break up the visible landscape. View from the Mississippi River bluffs (facing west) with floodplain farmlands in the background

148 Visual character in Segment 2 also changes from west to east. Segment 2 begins in the more heavily forested hills and valleys indicative of the area between the Mississippi and Illinois Rivers, passes through the heavily farmed floodplains of the Illinois River, and grows steadily more agricultural as the route continues east toward I-55. Smaller farms of variable shape intermix with the many forested drainages, providing variable view lengths and character. Southern Scott County, west of the Illinois River floodplain, smaller irregular farms are interspersed with forested drainages Agricultural land cover dominates the visual landscape in Macoupin County, as small forested drainages decline in prominence and broad uninterrupted views of farmland become more common. This gradual west to east increase in agricultural proportion varies between the northern and southern routes in Segment 2, with routes on the north generally transitioning more quickly to a larger proportion of farmland and routes on the south staying longer in the forest dominated lands between the rivers.

149 Northwestern Macoupin County, agricultural land use dominates the visual landscape in the eastern portion of Segment 2 Segment 3 begins in the predominately flat and heavily farmed landscape noted in the eastern portion of Segment 2. This visual character continues through northern Montgomery and southern Christian Counties. East of Pana, Segment 2 crosses through several major drainages, including Beck Creek, Kaskaskia River, Little Wabash River, Embarras River, and the North Fork of the Embarras River. At each major drainage, forest cover increases as arable land decreases, and farms of variable shape intermix with the many forested draws providing variable view lengths and character. Southern Shelby County, Beck s Creek drainage irregular farms surround major forested drainages in Segment 3

150 Existing transmission infrastructure becomes more notable in Segment 3, specifically south and east of Pana. Major transmission lines connect Pana, Neoga, and Casey, each crossing perpendicular to the major drainages that generally run north and south. One of these crossings, shown below, also crosses the Hidden Springs State Forest. Eastern Shelby County, existing 345 kv transmission ROW across Richland Creek and the Hidden Springs State Forest The Study Area narrows considerably by Segment 4, as the Alternative Routes converge on the eastern converter station and the Sullivan Substation just east of the Indiana state line. Land use along this final segment transitions from a mixture of farms and forested areas in the Little Creek drainage, to the intensive farm lands of the Wabash River floodplain. In the western portion of the Study Area, views are generally shorter and more varied. An existing 345 kv transmission line is a notable visible vertical feature in Segment 4 crossing through the forest drainages east of Little Creek and Mill Creek.

151 Clark County, existing 345 kv transmission ROW across Little Creek drainage The converter station is located along this existing line on a large parcel with forest lined edges at a bend in Mill Creek. The forested riparian area provides screening to the north, east, and west of the station. Forested riparian area along Mill Creek surrounding proposed converter station Land use east of the converter station is dominated by farming, providing long nearly uninterrupted views to the tree-lined Wabash River. The existing line, sporadic homes, and extensive use of pivot irrigation systems are the primary visual features.

152 Extensive farmlands in the Wabash River floodplain east of the converter station, Casey Breed 345 kv line in the foreground Viewer/User Groups Many factors influence the visual impact of any Alternative Route. The viewer is one of these factors. A viewer is defined as not only the person who is viewing the transmission line but also as the person s expectations, activities, and frequency of viewing the line (USDA Forest Service 1995). Three types of viewers were identified in the Study Area: Local Residents Local residents are those people who live in the area of the proposed transmission line. Residents may view the line from their yards or homes, while driving on local roads, farming, or during other activities in their daily lives. The sensitivity of local residents to the visual impact of the line may be mitigated over time by frequent exposure to existing transmission lines and other dissonant features already within the viewshed. Commuters and Travelers Commuters and travelers are people who travel by the transmission line on their way to other destinations. Typically, drivers have limited views of the transmission line where vegetation or buildings provide screening and where the line crosses high above the road surface. Under these conditions, the visual perception of the line for commuters and travelers is anticipated to be relatively low because they are typically moving and have a relatively short duration of visual exposure to the line. When new visual features persist in the immediate vicinity or directly parallel to the road over long distances, longer visual exposure can be expected. Recreational Users Recreational users include primarily local residents and visitors

153 involved in recreational activities, such as wildlife viewing, hunting, fishing, hiking, and camping. These areas are described in greater detail in Table For some recreational users, scenery may be an important part of their experience because their activities may include attentiveness to views of the landscape for long periods. Such viewers also may have a high appreciation for visual quality and high sensitivity to visual change. Scenic Integrity and Visual Absorption Scenic integrity is the degree by which the landscape character deviates from a natural or naturally appearing landscape in line, form, color, and texture of the landscape. In general, natural and naturally appearing landscapes have the greatest scenic integrity. As human-made incongruities are added to the landscape, scenic integrity diminishes. Additionally, some landscapes have a greater ability to absorb alterations with limited reduction in scenic integrity. Character and complexity, as well as environmental factors, influence the ability of a landscape to absorb changes. Scenic integrity refers to the degree of intactness and wholeness of the landscape character. For example, new transmission and substation facilities are more likely to blend-in with surroundings near pre-existing industrial facilities. A new transmission line sited next to an existing transmission line provides less contrast, and therefore, can be absorbed into that landscape better than introducing a transmission line as a new feature into a previously undeveloped area. The structure design itself could also have an impact on visibility and absorption. As described in Section 1.4, Project Description, a combination of lattice mast and monopole structures and lattice towers will be used for the Project. From a visual standpoint, lattice structures blend into the background, especially from the middle- and back-ground distances. The lattice design allows the natural colors of the surrounding backdrop to be seen, dissipating the visual intrusion of the transmission line. Monopole structures tend to stand out more on the landscape, compared with lattice structures. There are typically more monopole or lattice mast structures per mile than lattice structures. In areas where long vistas are possible, the use of monopole structures could lead to greater visible impacts, particularly in areas where a transmission line parallels a roadway, but the use of lattice mast structures would reduce this impact. The following table presents information on a range of visually sensitive features and factors useful for comparing potential for aesthetic impacts from the Project (Table 5-15 and Figure 5-5). This information was used to compare the potential visual impacts of each of the Alternative Routes with respect to the likely viewers, the existing visual character of the area, and its sensitivity to absorbing new vertical infrastructure in the visual landscape.

154 Table Visually Sensitive Features Resources Unit of Measure A B C D E F G H I J K L M N O P Q NRHP Properties/Sites within 1 mile Count National Scenic Byways Great River Road Description X X Historic Route 66 Description - - X X X X X Historic Route 66 (Route 4 loop) Description - - X X X X X National Historic Road Description X X X X X X X X - - Residences/Development Residences within 500 feet Count Populated places within 1 mile Count Populated places within 2 miles Route Considerations Count Route Length Length (Miles) Percent parallel to existing transmission lines Recreational Resources Percent 14% 0% <1% <1% <1% 0% 0% 38% 18% 20% 3% 36% 18% 21% 3% 100% 31% Sites w/in 1 mile Count Sites w/in 2 miles Count

155 Figure 5-5A. Recreational Resources in Segments 1 and 2

156 Figure 5-5B. Recreational Resources in Segments 3 and 4

157 General Impacts During construction of the Project, the rural setting and the scenic integrity of visually sensitive sites near the line may be impacted due to increased construction-related traffic, noise, dust, brightly colored signage, and the increased number of people coming to the area. Large cranes and/or helicopters are typically used during the construction of transmission lines, creating an increased temporary disturbance in the visual, aesthetic, and peaceful nature of some areas; however, these are short-term disturbances and would cease when construction ends. Over the long term, the transmission structures, and to a lesser extent the conductor, would become a new piece of industrial infrastructure added to the visual character of the area the line occupies. Any impacts to the overall character of the area would last for the life of the line and would vary by land type and viewer. The following section provides a discussion of the differences in potential visual impacts between the Alternative Routes. Alternative Route Comparison Segment I The most visible portion of the Project in Segment 1 would be the crossing of the Mississippi River itself. Structures at the river would be significantly taller than structures anywhere else on the line in Illinois and would likely be lit to meet Federal Aviation Administration requirements. Although the river is lined by forest cover, the height and lighting of the structures would be visible above the tree line and likely visible for several miles. Because both Alternative Routes cross at the same location, neither would be any more or less visible at this location. Alternative Routes A and B diverge immediately after the river crossing, heading eastward along two different but parallel paths separated by 0.5 mile. After approximately 5 miles, the two lines diverge, with Alternative Route B turning due south, while Alternative Route A follows along its original due east trajectory through the floodplain and into the bluffs. Just over a mile to the east of this divergence, Alternative Route A crosses over the existing Ameren 115 kv line, that runs from northwest to southeast parallel to U.S. 96, passing just over a half mile south of New Canton. Structures at the crossing of this existing transmission line will need to be tall enough to safely pass over the existing line and would therefore likely be more visible from the small community of New Canton. The town hosts one historic site, the Massie Variety Store, which is within 1 mile of this crossing location, but with relatively flat terrain and the many buildings in between the store and the crossing, it is not likely that the line would be viewable from this resource. Alternative Route A crosses the Great River Road just east of the Ameren 115 kv line crossing. Views from the road at this location are long and broad owing to the flat expanse westward and limited tree cover. However, views at this location are already impacted by the existing lattice Ameren line and would be transient as the viewer travels along the road.

158 Alternative Route B turns due south from the point of divergence from Alternative Route A continuing along that trajectory for 1.5 miles before turning due east and following along parcel boundaries to the bluffs approximately 3.5 miles to the east. The turn south along the west side of 220 th street would result in the line being more conspicuous to travelers along the Great River Road at this location; however, the existing Ameren 115 kv lattice structures and line run roughly parallel to the road in this area and would be in the foreground of these views, limiting the overall impact of the new line on the current visual character. Alternative Route B heads due east along the north side of 230 th Ave, continuing along parcel boundaries into the bluffs crossing over the Ameren 115 kv line approximately 0.4 mile before reaching the bluffs. Similar to Alternative Route A, structures at the crossing of this existing transmission line will be taller and therefore more visible to travelers on the Great River Road; however, Alternative Route B is much farther from the Town of New Canton, and this crossing point is 3 miles southeast of the town and would not likely be visible. Both Alternative Route A and B cross into the forested bluffs above the floodplain roughly perpendicular to the toe of the bluff slope. Alternative Route A angles to the southeast upon entering the bluffs to parallel a small existing transmission line (wood H frame type) for approximately 1.8 miles, continues east across forest lands (not on existing parcel boundaries) for another 1.5 miles before turning due south to meet up with the Alternative Routes in Segment 2. Alternative Route A is close to several existing homes along this trajectory upon entering the bluffs, at the crossing of County Highway 13 and while paralleling the existing transmission line (however, current views include the existing line). In addition, Alternative Route A also crosses in proximity to a potential future home site along the bluff ridge line. This site was identified by a local landowner at the public meetings who had recently constructed a driveway to the site in the last year. Although the timing of construction of the home is not known at this time, the driveway up to the ridge was developed to ultimately support that purpose. Alternative Route B continues along parcel boundaries due east to its connection point with the Alternative Routes in Segment 2. Its path comes close to two homes the first at the toe of the bluff slope along Highway 96 and the second farther into the bluffs along 265 th Street. In general, the residential density through this area is less than that farther north and near the Town of New Canton and forest cover and topography would limit viewshed impacts to small localized areas. In summary, Alternative Route A is closer to New Canton and El Dara where it will require taller structures to cross the existing 115 kv line and has more homes in proximity (including a planned future home site) than Alternative Route B. Although Alternative Route B parallels Great River Road for a short distance, increasing the duration for recreational viewers, the presence of the existing line in the foreground would partially mitigate these impacts. Taken

159 together, the two routes would have similar impacts, but Alternative Route B would likely have less impact on visual resources than Alternative Route A. Segment 2 Segment 2 begins in the more heavily forested hills and valleys indicative of the area between the Mississippi and Illinois Rivers, passes through the heavily farmed floodplains of the Illinois River, and grows steadily more agricultural as the route continues east toward I-55. Alternative Routes through Segment 2 generally either follow: a northern path that runs just south of Pittsfield, north of Roodhouse, and just south of Virden (Alternative Route C); a southern path that runs south of White Hall, just north of Camp Bun, and south of Girard (Alternative Routes F and G), or a combination of the two (Alternative Routes D and E). None of the Alternative Routes in Segment 2 are close to major public developed recreation resources, the lengths of the routes are generally similar, and none parallel existing infrastructure. The primary differences between the two routes, with respect to factors that relate to the potential for visual impacts, is their proximity to homes, proximity to small communities, relative land use proportion, and crossings of the designated scenic Route 66. The Alternative Routes on the northern portion of Segment 2 have a greater proportion of agricultural lands, with more frequent, long and broad views that are more easily impacted by new vertical infrastructure (less visual absorption capacity). In contrast, Alternative Routes on the south have more variable topography and more contiguous forest areas both of which limit the length and breadth of views and provide natural screening. In these areas, the impact of the transmission line would be less visible and views would be more transient. Alternative Routes that are on the north for the first half of the segment have both more broad views and are near more small towns than those on the south. At the same time, the southernmost routes, Alternative Routes F and G, are close to more homes (11 within 500 feet) when compared to the northern routes, most notably the most northern route, Alternative Route C (8 residences within 500 feet). Thus, although the northern routes have more frequent long broad views and are generally closer to more communities, the southern routes are more frequently close to individual homes. Several historic and potentially historic properties fall within the viewshed of the Alternative Routes to the south through this segment. The Scott Lyman House (listed on the National Register), on the outskirts of Summer Hill, is approximately 1 mile from Alternative Routes F and G. Given the distance, it is not anticipated that this would have a significant impact on the viewshed of the property. Farther to the east along these routes, the Project crosses U.S. Route 67 south of White Hall. There are potentially historic properties from the mid-1850s near this crossing that were identified in state historic data, during route reconnaissance, and at public meetings. Original alignments through this area were modified to have a lesser impact on the viewsheds of these properties; however, the addition of a new industrial element in

160 these pastoral views would alter the character of the landscape through this area. If determined historic, additional consultation and coordination with the Illinois State Historic Preservation Office would be required to determine the need for and type of any mitigation measures. All of the Alternative Routes cross two different segments of historic/scenic Route 66. The western leg of Route 66 follows the historic path of the road along State Route 4 (and other smaller roads), while the eastern leg is a more contemporary scenic recreational route along I- 55. Alternative Route C continues along a northern path through this portion of the segment, crossing the first segment of Route 66 just south of Virden, near Ameren s Pawnee Virden 115 kv line and the Virden Substation. In this area, the existing visual character already includes an existing transmission line, distribution lines, a nearby cell tower, and a substation. Any additional impacts at this location would therefore be considered incremental with respect to the current visual character at the crossing. The remaining Alternative Routes through this segment cross the more historic alignment of Route 66 just south of Nilwood. Alternative Routes E, F, and G all pass through this area, which is flat and extensively cultivated. The crossing point includes grain bins and other farm associated infrastructure but generally has broad views save for a small line of trees to the east. Because the new line would be a noted change in the view through this area, it would unavoidably alter the character scene for viewers passing by this crossing. The northern Alternative Routes cross the more contemporary scenic Route 66 route along I- 55 through a flat landscape of extensive farmlands in northern Montgomery County. The landscape through this area offers broad, uninterrupted views of cultivated lands in all directions and the visual absorption the new line would be limited at this crossing. The crossing on the southern routes, however, passes on the northern side of a rest area for I-55. The line at this location would also be distinct and alter the character of the view, although the presence of the rest areas, parked vehicles, signs, and parking lot lighting would likely distract the viewer from focusing on the distinctness of the new line. Taken together, the Routing Team considered no segment significantly better than another with respect to the potential for visual impacts. Although Alternative Routes on the south in the western portion of the segment had better screening and fewer towns in proximity, they had the greatest number of residences in proximity. Although the northern routes had better crossings of scenic roads and avoided potentially historic viewsheds, they passed by a greater number of towns and had a greater proportion of cultivated land use potentially providing more long distance views of the line. Segment 3 The Alternative Routes through Segment 3 begin just east of I-55 in the flat, extensively farmed landscape of southern Christian County and northern Montgomery County. Few visually

161 sensitive resources are found in this area, and residential density is generally low. However, long, uninterrupted views would allow for the new line to be more visible through this area for both northern (Alternative Routes H, I, J, and K) and southern routes (Alternative Routes L, M, N, and O). The southern routes pass within 1 mile of eight small communities, as compared to four for the northern routes. The southern routes pass just north of Nokomis, the largest community in this segment, adjacent to an existing quarry. The alignment through this area was developed adjacent to the quarry and along 22 nd Avenue to take into consideration future quarry plans for expansion. As a result, the line will be placed adjacent to, and ultimately surrounded by, the quarry and its associated crane booms and infrastructure likely minimizing the overall visual contrast of the line through this area. Taken together, both the northern and southern routes pass through areas with little existing infrastructure and have relatively few residences in close proximity; however, Alternative Routes L, M, N, and O pass in close proximity to more communities than Alternative Routes H, I, J, and K and would likely have a greater overall impact on area aesthetics. South and east of Pana, the proportion of forest cover increases as the routes pass through the headwater tributaries of the Kaskaskia and Little Wabash Rivers in Shelby County toward Neoga. Existing transmission lines cross the segment heading toward Neoga and Greenup from Pana in southern Shelby County and the Ramsey Substation in northern Fayette County. Those routes that stay along the north side of the Study Area through this portion of the segment (Alternative Routes H, I, L, and M) pass just south of Pana, while heading east to parallel the Neoga Shelbyville 138 kv line. Routes through this area require many small shifts and turns to avoid more frequent residences along the eastward path to reach the 138 kv line, likely adding to the overall visual disturbance for the larger density of local landowners. Once the northern Alternative Routes reach the existing Neoga Shelbyville 138 kv line, however, the overall impact of the new line is diminished as a result of the existing line and its current effect on the visual character in the area immediately surrounding it. A historic site, the Clarksburg Schoolhouse, is roughly 0.5 mile from the routes along this parallel alignment. It is not anticipated that any additional impact of the new line would significantly alter the historic context of the school house given the presence of the existing line. Farther east, the Hidden Springs State Forest is crossed along the existing 138 kv line. Although visual impacts at this location would be muted by the presence of the existing line, the additional clearing and opening of the forest canopy along the Richland Creek valley will be notable for those hiking trails on the forest to the north. The southern alternatives in the central portion of Segment 3 (Alternative Routes J, K, N, and O) follow closely along parcel boundaries through areas of lower residential density close to the southern boundary of Shelby County. Topographic variability and vegetative screening are limited in this portion of the segment, though residential density, public recreational use, and the availability of major transportation routes is low, limiting the number of viewers that would see the change in visual character. The routes pass north of the Village of Cowden, where

162 visual accessibility would likely be greatest, and continue eastward along the southern edge of a large contiguous forest area along Richland Creek and the forested riparian areas of Bruch Creek drainage. Topographic variability and forest cover increase making potential views of the new line less frequent and more transient east of Cowden. Summarizing the comparisons in the central portion of Segment 3 suggests that the southern routes would have a lesser overall impact on visually sensitive resources. The northern routes (Alternative Routes H, I, L, and M) impact more residences and pass near more communities while only having a portion of the visual impacts reduced by the presence of an existing line. In contrast, the southern routes in the central portion of Segment 3 (Alternative Routes J, K, N, and O) pass through areas of generally lower residential density, have fewer homes in close proximity, and east of Cowden have terrain and vegetative screening that will help to reduce the contrast and visual frequency of views of the line. The northern and southern Alternative Routes converge in the eastern third of Segment 3. The northern routes divert south from a parallel alignment due to a number of homes immediately adjacent to the existing 345/138 kv corridor (the Neoga Casey 345 kv and Hutsonville Neoga 138 kv lines). Through this stretch of Segment 3, the northern and southern routes follow along parallel alignments separated by just over a mile. The area is extensively cultivated with several large specialty producers of seed and landscaping vegetation. Both alignments through this area would alter the visual character of its immediate area; however, the network of existing transmission converging on the Neoga Substation (located halfway between Neoga and Sigel) would lessen the overall contrast of the new line in the area landscape. The northern (Alternative Routes H, J, L, and N) and southern routes (Alternative Routes I, K, M, and O) of the easternmost one-third of Segment 3 diverge from one another passing on either side (north/south) of Greenup. The scenic National Historic Road passes through the area from southwest to northeast. Both the northern and southern routes are aligned adjacent to existing lines through this area to avoid creating a new crossing of industrial infrastructure along the national scenic road. The northern routes also cross the Lincoln Trail Motosports facility, a motorcycle and ATV riding park. Given the presence of the existing line through the facility and non-natural setting of the recreational activity, the new line would not likely have significant impacts on the scenic integrity of the site. The northern routes continue east in a predominately parallel alignment along the existing transmission line, diverting three times to avoid homes and planned expansion of an existing quarry. In general, the visual impacts of the new line would be considered reduced when compared to a non-parallel alignment, given the impacts of the existing line. The southern routes beyond Greenup, head east along a largely contiguous parcel boundary alignment that begins in predominately agricultural lands and gets progressively more forested moving eastward. The area has generally low population and residential density, but the long, broad views of the line will be in contrast to the current visual

163 character in agricultural area, with periodic areas of lesser visibility through forested drainages farther east. Segment 4 The Alternative Routes of Segment 4 begin approximately 7 miles due west of the proposed converter station location. The northern route, Alternative Route P, follows along the southern side of Ameren s Casey Breed 345 kv line, along a tight, consistent parallel all the way to the converter station. At the converter station, the line switches to the northern side of the existing line and crosses the Wabash River floodplain. Even though four houses are close to the existing line along Alternative Route P, these residences are already in view of the existing line. Thus, visual impacts of the new line along this alignment are anticipated to be minor given the effects of the existing line. In contrast, the southern route, Alternative Route Q, follows a parallel path less than a mile to the south of the existing line along predominately parcel boundaries to the converter station. Few residences are in proximity to the line in this segment and forest vegetation provides some level of screening; however, several cultivated areas would allow for broad views of the line. Some of these views may include the existing line farther in the background, but others will be completely new views in the landscape. Farther east in the Wabash River floodplain, several pivots will require taller structures to avoid impacts to their operation. These structures would be more visible and be in contrast to the regularity of the structures of the existing line increasing visibility. Although in general visual impacts in this area should be relatively similar, given the proximity of both routes to each other and the existing 345 kv line, the overall visual impacts of Alternative Route P are likely to be less than those of Alternative Route Q Cultural Resources Archaeological Resources The Routing Team reviewed site-specific and locational data, received from the Illinois State Museum, for archaeological sites, architectural resources, and historic properties listed on the National Register. Prehistoric development within Illinois was heavily influenced by the variation in the natural environment, resource distribution, and the challenges presented by the ever changing social environment. Archaeologists have divided the pre-european history of human occupation of Illinois into five major periods: Paleoindian Period (circa 12,000 to 8,000 years Before Christ [B.C.]); Archaic Period (circa 8,000 to 1,000 B.C.); Woodland Period (circa 1,000 B.C. to 900 Anno Domini [A.D.]); Mississippian Period (900 to 1450 A.D.); and Late Prehistoric Period (1450 to post-1700 A.D.).

164 A majority of Paleoindian sites in Illinois represent shortly occupied camps; people from this period are generally believed to have lived in small, highly mobile groups. The Woodland Period in Illinois is marked by plant domestication, population increase and the invention of pottery and the bow and arrow. People gradually became more sedentary, formed organized villages and concentrated settlements within major river valleys. Woodland Period sites include elaborate grave offerings placed within mound and village burials. During the Mississippian Period, hierarchical societies formed within various river valleys and held considerable regional influence. A continued reliance on maize agriculture made it more feasible to settle in one location year-round. Farmsteads and hamlets surrounded and provided food for centralized cities, many of which were fortified and contained large earthen structures. Widespread site abandonment and population migration marks the end of the Mississippian Period. Settlements were much smaller and large areas of land once inhabited remained unoccupied for centuries. In the 17 th century, Europeans came into contact with two ethnic groups in Illinois: the Illinois, a collection of twelve tribes, and the Miami tribe. It wasn t until the 18 th century that the Fox, Ioway, Kickapoo, Mascouten, Piankashaw, Potawatomi, Sauk, Shawnee, Wea and Winnebago tribes migrated into Illinois. Starting in the 19 th century, following failed French and British occupations, heavy European immigration transformed Illinois into an agricultural and manufacturing center. Two archaeological sites have been previously identified within the ROW of the Alternative Routes in Segment I of the Project. These sites consist of a Late Archaic Period site and a Woodland Period habitation site. Approximately 16 previously identified archaeological sites have been identified within 1,000 feet of Segment I. These sites are predominantly prehistoric habitation sites. One previously identified prehistoric site within Segment I also contains human remains and/or grave goods associated with unmarked burials. The proximity of the Mississippi River suggests the potential for Paleoindian Period and deeply buried deposits. One historic archaeological site is located within the vicinity of Segment 1; it is a habitation site of an unknown occupation period. A total of 12 archaeological sites have been previously identified within the ROW of the Alternative Routes in Segment 2 of the Project. These sites consist predominantly of prehistoric habitation sites and Woodland Period mound sites. The three mound sites and three multicomponent prehistoric/historic sites contain human remains and/or grave goods associated with unmarked burials. Approximately 60 archaeological sites have been identified within 1,000 feet of Segment 2. These sites consist of nearly six prehistoric sites for every historic site. Roughly half of the prehistoric sites could not be identified with a period of occupation. The prehistoric sites mainly consist of habitation sites and there are 14 mound sites, 12 of which are associated with the Woodland Period. All of the mound sites and three

165 multicomponent prehistoric/historic sites contain human remains and/or grave goods associated with unmarked burials. Roughly a sixth of the prehistoric sites are of an unknown site type and 11 sites are isolated finds. The proximity of the Mississippi River suggests the potential for Paleoindian Period and deeply buried deposits. The historic archaeological sites identified within the vicinity of Segment 2 consist of Pioneer, Frontier, Early Industrial and Urban Industrial habitation and commercial sites. Roughly one-third of the historic archaeological sites could not be identified with a period of occupation. A total of 4 archaeological sites have been previously identified within the ROW of the Alternative Routes in Segment 3 of the Project. These sites consist entirely of prehistoric habitation and mound sites. All four of the mound sites contain human remains and/or grave goods associated with unmarked burials. Approximately 18 archaeological sites have been identified within 1,000 feet of Segment 3. These sites consist of nearly 4 prehistoric sites for every historic site. Roughly half of the prehistoric sites could not be identified with a period of occupation. A plurality of prehistoric sites are habitation sites and there are 8 mound sites, none of which can be attributed to an occupation period. All 8 of the mound sites contain human remains and/or grave goods associated with unmarked burials. Roughly a fifth of the prehistoric sites are of an unknown site type and 8 sites are isolated finds. Numerous rivers intersecting the Project ROW suggests the potential for Paleoindian Period and deeply buried deposits. The historic archaeological sites identified within the vicinity of Segment 3 consist of Early Industrial habitation sites. Roughly three-fourths of the historical archaeological sites could not be identified with a period of occupation. One archaeological sites has been previously identified within the ROW of the Alternative Routes in Segment 4 of the Project. The site consists of Late Woodland and Mississippian period occupations and is a multipurpose mound and habitation site. It also contains human remains and/or grave goods associated with unmarked burials. Approximately 7 archaeological sites have been identified within 1,000 feet of Segment 4. These sites are predominately prehistoric sites and one is a historic Native American site. Two prehistoric sites consist of Paleo-Indian Period deposits and two sites could not be identified with a period of occupation. Roughly half of the prehistoric sites consist of habitation sites. There are two prehistoric cemeteries and two prehistoric mound sites, all of which contain human remains and/or grave goods associated with unmarked burials. The proximity of the Wabash River suggests the potential for additional Paleoindian Period and deeply buried deposits. The historic Native American site is a cemetery and consists of human remains and/or grave goods associated with unmarked burials.

166 Architectural Resources Segment 1 of the Project running through the northwest corner of Pike County has few known architectural resources (Figure 5-6A). A general store in the Town of New Canton is the only architectural resource identified (Table 5-16). The broad flood plain of the Mississippi River contains numerous farmsteads and likely rural residences. New Canton and El Dara are the only towns located near Segment 1 (Table 5-11). Segment 2 consists of the eastern half of Pike County, Scott, Greene, Macoupin, and Montgomery Counties (Figure 5-6A). These counties include rural farmsteads, residences, commercial buildings, cemeteries, churches, bridges, and schools. The early settlement of the area is reflected in the domestic architectural styles such as Greek Revival, Second Empire, Italianate and Queen Anne and common vernacular forms including gabled-ell and I-house. Rural schools and churches are generally frame construction. The farmsteads within the Study Area also follow folk types and styles. There are numerous known sites located in the Study Area including bridges and residences in both rural and urban settings (Table 5-16). The towns located near or within Segment 2 are shown in Table Segment 3 consists of Montgomery, Christian, Shelby, Cumberland, and Clark Counties (Figure 5-6B). These counties have rural resource types similar to those found in Segment 2. Domestic resources in this segment are also characterized by vernacular forms such as the gabled-ell, I-house, and double pile. The farmsteads within the Study Area also follow folk types and styles. U.S. Highway 40 (National Road) is located within this segment. Numerous known sites are located in the Study Area including bridges and residences in both rural and urban settings (Table 5-16). The towns located near or within Segment 3 are shown in Table Segment 4 is entirely within Clark County (Figure 5-6B). There are only two known sites located within the Study Area including a farmstead and a rural school (Table 5-16). The floodplain of the Wabash River contains many farmsteads, which follow the folk types and styles of Segments 2 and 3. The towns located near or within Segment 4 are shown in Table 5-14.

167 Table Cultural Resources Alternative Routes Archeological Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Resources within the ROW Resources within 1,000 feet Alternative Routes (distance in feet) Architectural 1 Massie Variety Store (NR Listed) Scott Lyman House (NR Listed) Thompson Mill Covered Bridge (NR Listed) Clarksburg Schoolhouse (NR Listed) Cumberland County Courthouse (NR Listed) Bridge over Little Sandy Branch (NR Eligible) Bridge over Apple Creek (NR Eligible) Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q 5, ,240 5, ,130 5, ,130 5, ,530 1, ,530 1, , ,480-4,480-4, ,370 1,370 1, Resources are measured from centerline of the Alternative Routes.

168 Figure 5-6A. Architectural Properties in Segments 1 and 2

169 Figure 5-6B. Architectural Properties in Segments 3 and 4

170 General Impacts and Mitigation Transmission lines tend not to have significant direct impacts on archaeological resources, which are usually located entirely below the ground surface. However, some sites have surface expression, such as burial mounds, effigies and intaglios, stone circles or alignments, foundations and walls, and cemeteries. The new transmission structures might detract from the setting or feeling of a site, particularly if the significance of the site relates in part to a sense of wildness, openness, primitiveness, or sacredness. Whenever possible, adverse impacts on identified sites would be avoided by strategically locating access roads, staging areas, and structures. Impacts on archaeological properties may be physical and/or visual, depending on the type of site. Visual impacts, such as those described for architectural historic properties, can occur where the physical setting, location, or feeling contributes to the significance of the resource. Frontier military posts or homesteads, battlefields, historic trails, cemeteries, burial mounds, or landforms that are identified as sacred places are some examples. Adverse physical impacts can include ground disturbance by excavation to construct transmission line support structures and substations, compression and/or rutting by heavy machinery, grading/constructing access roads, pulling stumps, material storage, or surface collection of artifacts by construction crews. Impacts on architectural historic properties would be primarily visual, created by the construction of new structures where none exist, the addition of a second transmission line next to an existing transmission line corridor (generally a lesser impact), and clearing of forested land. Impacts would vary based on local relief, height of existing vegetation, and any intervening recent development. Any physical impacts on architectural historic properties would be avoided, where possible, by strategically locating access roads, staging areas, and structures. Alternative Route Comparison A review of archaeological resources within the Illinois Inventory of Archaeological Sites provided by the Illinois State Museum identified a total of 19 recorded archaeological sites along one or more of the Alternative Routes. Generally, archaeological resources are only a concern when located within the ROW and can usually be spanned or avoided, eliminating any impacts. A review of the National Register and the Illinois Inventory of Archaeological Sites was completed for each segment. Spatial information was collected on all previously identified architectural and archaeological resources within 0.25 and 0.5 mile of each Alternative Route. A review of the archaeological resources provided by the Illinois State Museum identified no National Register-listed archaeological properties within 0.5 mile of the Alternative Routes. Segment I Alternative Routes A and B each have one archaeological resource within the ROW and nine and ten, respectively, archaeological resources within 1,000 feet (see Table 5-16). Very little

171 of the Project ROW for this segment has been previously surveyed either intensively or systematically. In addition, a majority of the Project ROW for both Alternative Routes, according to information from the Inventory of Illinois Archaeological Sites, overlap areas of high archaeological resource potential. Portions of Segment I, therefore, may contain additional resources that have not yet been identified. The National Register-listed Massie Variety Store in New Canton was identified approximately 1 mile from Alternative Route A. Alternative Route B does not have any known resources within 1 mile of centerline. Segment 2 Alternative Routes D and E have the greatest number of previously identified archaeological resources located within the ROW, with 8 each, but the overall variance among all of the Alternative Routes is not high (see Table 5-16). Each of the Alternative Routes, according to information from the Inventory of Illinois Archaeological Sites, only intermittently crosses areas of high archaeological resource potential, typically land along rivers or tributaries. The high frequency of archaeological resources identified by surveys conducted previously by other entities within the Project ROW and/or land adjacent to it for all of the Alternative Routes, however, suggests that the large portions of the Project ROW not previously surveyed may contain unidentified resources. Alternative Routes C, D and E cross an archaeological site containing 15 individual mounds and protected archaeological resources. The site is crossed by five existing pipelines and has been surveyed extensively; however the surrounding areas have not been entirely surveyed, suggesting that this site may be more extensive than currently recorded. In addition, there is a 5,000-foot portion within both Alternative Routes E and G that has five relatively large archaeological sites within 1,000 feet of the Project ROW and is situated in an area that has not been extensively or systematically surveyed. Grain Belt Express will consult with the Illinois Historic Preservation Agency to determine protection measures necessary to avoid or minimize impacts to known or undiscovered archaeological resources. One National Register-listed site is located within 1 mile of Alternative Routes F and G (Table 5-16). The National Register-listed Scott Lyman House is approximately 5,240 feet from Alternative Routes F and G. The recorded sites include three bridges, a bandstand in the Village of Time, and two rural residences within 0.50 mile of Alternative Routes C, D, and E (Table 5-16). Alternative routes C, D, and E pass within 1,000 feet of the Bridge over Little Sandy Branch and within 1,500 feet of the Bridge over Apple Creek, both National Registerlisted. Six additional recorded resources in the Village of Virden are between 0.50 mile and 1 mile of Alternative Route C. Three recorded rural residences are within 0.50 mile of Alternative Routes F and G.

172 Segment 3 A total of 4 archaeological resources are located within the ROW for Alternative Routes in Segment 3 (see Table 5-16). Alternative Route M has the greatest number of previously identified archaeological resources, with 4, but the overall variance among all of the Alternative Routes is not high. All of the Alternative Routes, according to information from the Inventory of Illinois Archaeological Sites, only intermittently cross areas of high archaeological resource potential, typically rivers or tributaries. Like Segment 2, numerous long linear surveys that intersect or are within a half mile of the Project ROW have been conducted previously by other entities. Most of the Project ROW, however, has not been surveyed and therefore unidentified archaeological resources could occur within the Project area. An archaeological site, consisting of 17 small mounds atop a bluff, is bisected and oriented in the same east-west direction as a portion of the Project centerline within Alternative Routes I, K, M, and O that spans approximately 3,000 feet. In addition, five archaeological sites are located within 1,000 feet of a 1,500-foot portion of the Project ROW within Alternative Routes H, I, L and M. Although this entire portion of the Project ROW was extensively surveyed in the past, only the ground surface was surveyed and there is potential for the presence of undisturbed subsurface archaeological resources. Grain Belt Express will consult with the Illinois Historic Preservation Agency to determine protection measures necessary to avoid or minimize impacts to known or undiscovered archaeological resources. Segment 3 has three National Register-listed resources located within 1 mile of the Alternative Routes (Table 5-16): the Clarksburg Schoolhouse is located just over 0.50 mile from Alternative Routes H, I, L, and M; the Cumberland County Courthouse is within 1 mile of Alternative Routes H, J, L, and N; and the Thompson Mill Covered Bridge is located within 1 mile of Alternative Routes J, K, N, and O. Numerous recorded resources are located within 0.25 mile of Alternative Routes I, K, M, and O. Alternative Routes H and L have one previously recorded resource within 0.25 mile. The Rosamond Grove Cemetery is located within 1 mile of Alternative Routes H, I, J, and K. The cemetery also contains a Civil War-era cannon and Statue of Lincoln. However, very few of these sites have been evaluated with respect to National Register criteria. Segment 4 Alternative Routes P and Q each have one archaeological resource within the ROW and 14 archaeological resources within 1,000 feet (see Table 5-16). The entire Project ROW for this segment has not been previously systematically surveyed and, according to information from the Inventory of Illinois Archaeological Sites, it is within an area of high archaeological resource potential. Portions of Segment 4, therefore, may contain additional resources that have not yet been identified. As stated previously, Grain Belt Express will consult with the Illinois Historic

173 Preservation Agency to determine protection measures necessary to avoid or minimize impacts to known or undiscovered archaeological resources. No National Register-listed resources are located within 1 mile of Alternative Routes P and Q. Only one previously recorded resource, the Happy Haven Farm, is located within 0.50 mile of Alternative Routes P and Q. However, the farm was not evaluated with respect to National Register criteria Built Environment Summary Segment 1 In Segment 1, Alternative Route B would have less impact on the built environment than Alternative Route A. Both Alternative Routes will result in similar impacts to developed land, agricultural land, the existing viewshed and cultural resources. However, Alternative Route B avoids passing within 250 feet of any residences, runs along parcel boundaries for a greater distance, and avoids bisecting several large farms with significant pivot irrigation infrastructure. Segment 2 In Segment 2, Alternative Route C will impact the built environment less than the remaining four Alternative Routes. Alternative Route C is slightly shorter than the other Alternative Routes, crosses the Illinois River adjacent to an existing pipeline, and has fewer residences within 500 feet. Alternative C is anticipated to result in similar impacts to agricultural land, the existing viewshed, and cultural resources compared to the remaining Alternative Routes. Segment 3 Based on evaluating the eight Segment 3 Alternative Routes, Alternative Route K will impact the built environment less than the remaining Alternative Routes. Alternative Route K avoids crossing the incorporated boundaries of any municipalities, runs along parcel boundaries for the greatest distance (54 percent of its route), has the fewest residences within 250 and 500 feet, and crosses fewer small parcels. Alternative Route K would have less of an impact than the other Alternative Routes on agriculture because it minimizes bisecting farms by running along parcel boundaries. Alternative Route K also avoids crossing an environmentally sensitive area on public lands and is expected to result in similar impacts to cultural resources compared to other Alternative Routes. Segment 4 Based on evaluating the two Segment 4 Alternative Routes, Alternative Route P would impact the built environment less than Alternative Route Q. Alternative Route P is slightly shorter than Alternative Route Q, parallels an existing transmission line for 100 percent of its route, and passes within 500 feet of only a few residences that are also already near the existing line. From an agricultural perspective, Alternative Route P crosses fewer acres that employ center

174 pivot irrigation, and would not impact the operation of those pivots crossed. Alternative Route P would result in similar impacts to cultural resources compared to Alternative Route Q. 5.3 Engineering and Constructability Impacts Constructability is a term used to describe the feasibility of a proposed transmission line as it relates to engineering and construction concerns. Constructability evaluates the use of existing transmission corridors, engineering challenges, and accessibility issues of a Proposed Route. Major factors that affect constructability include, but are not limited to, steep topography, condensed ROWs, high angles, proximity to major highways, accessibility, and cost. Additional issues to consider when evaluating constructability are: ease of moving equipment, materials, and workers to the construction sites; relative ease of ensuring public and worker safety; logistical difficulties associated with obtaining the required easements for the transmission line; and the actual amount of time and materials needed for construction, which can correlate to the total length of the corridor (i.e., longer lines require more materials and, often, a longer construction period). A comparison of the engineering and construction considerations for the Alternative Routes is presented in Table 5-17.

175 Engineering Table Engineering and Constructability Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q Length Parallels Transmission (miles) Parallels Road/ Railroad (miles) Sited Along Parcel Boundaries (miles) (14%) (30%) (<1%) 0.2 (<1%) 0.2 (<1%) (38%) 17.5 (18%) (21%) 40.5 (49%) 39.3 (46%) 37.5 (44%) 34.0 (40%) 32.1 (38%) 35.2 (38%) 46.7 (49%) 20.2 (20%) 43.2 (43%) 2.6 (3%) 52.6 (53%) 35.1 (36%) 34.9 (36%) 17.5 (18%) 46.3 (47%) 20.2 (21%) 39.9 (41%) 2.6 (3%) 49.3 (51%) 11.0 (100%) (31%) 2.2 (19%) Angled Structures 6 (#) Karst Topography (miles) Steep Slopes 15-1,160 1,160 5,490 6,010 6,010 9,780 9,780 1,320 1, ,090 1,380 1,520 1,020 1, % (feet) Steep Slopes >20% ,180 2,210 2,210 3,560 3, (feet) 60 Inactive Mines - Crossed (miles) In many cases, a single landowner owns one or more contiguous parcels. In these cases, the contiguous parcels were counted as a single parcel when calculating the distance sited along parcel boundaries.

176 5.3.1 Paralleling and Crossing Existing Linear Features Where feasible and logical, significant efforts were made to align Alternative Routes parallel to the existing transmission network and pipelines, and to run along parcel boundaries (discussed in Section 5.2). The Routing Team also attempted to avoid sharp angles and circuitous alignments in order to reduce overall cost of construction. Paralleling existing linear utilities consolidates utility corridors, logically placing a new land use feature in close alignment with an existing similar land use feature, thereby avoiding the fragmentation of existing land uses and sensitive habitats throughout an area. In addition, paralleling existing transmission lines can reduce the overall impact of the new transmission line on visually sensitive areas (e.g., historic sites and outdoor recreational areas) and airfield flight zones, since any impacts of the new line are considered in the context of the impacts of the existing line. In these areas, the impacts of the new line are considered incremental to the existing impacts, rather than completely new impacts in otherwise unaffected areas. Existing infrastructure paralleled throughout the Study Area includes: Ameren Illinois Shelbyville-Pana 138 kv transmission line Ameren Illinois Neoga-Shelbyville 138 kv transmission Line Ameren Illinois Hutsonville-Neoga 138 kv transmission Line Ameren Illinois Neoga-Casey 345 kv transmission line Ameren Illinois Casey-Breed 345 kv transmission line Ameren Illinois 115 kv transmission line Ameren Illinois Neoga-Effingham 138 kv transmission line Prairie Power, Inc. 138 kv transmission line in Pike County General Best Management Practices A few construction and engineering issues should be considered when paralleling existing infrastructure. During construction, outages may be required in specific situations when crossing other major lines. Outages are often difficult to schedule due to peak use seasons (summer and winter) when utilities are unable to take lines out of service. In addition, there are areas where existing transmission lines will be crossed. The proposed line will be constructed over the top of existing transmission lines and will require taller structures to provide for adequate clearance between the conductors. Existing pipelines are similar to existing transmission lines in terms of ROWs. The utilities can abut ROWs but not overlap them. Subsurface surveying may be required to determine the exact location of the pipelines prior to construction. Steel plating or matting may also be

177 required when crossing over the top of pipelines to protect them from large construction vehicles. Alternative Route Comparison Segment 1 Both Alternative Routes A and B run along parcel boundaries for a portion of their routes (Table 5-17). However, Alternative Route A also parallels 1.8 miles of existing transmission line. In total, Alternative Route A parallels existing transmission and runs along parcel boundaries for more than 6 miles (47 percent of its total length) and Alternative Route B parallels existing transmission and runs along parcel boundaries for just under 6 miles (43 percent of its total length). The number of transmission and pipeline crossings for the Alternative Routes in Segment 1 is shown in Table Both Alternative Routes cross the same number of 115 kv transmission lines and pipelines. Alternative Route A crosses one additional 69 kv transmission line. The pipeline corridor will likely be able to be crossed by a single span at the crossing location. The impacts from either Alternative Route are comparable. Although Alternative Route A parallels a short distance of existing transmission line, it does so by traversing a greater distance through the Mississippi River bluffs. Segment 2 Alternative Routes C, D, and E parallel existing transmission lines for a short distance along the length of the route in Segment 2 (Table 5-17). Each parallels the Tap Alsey 115 kv transmission line for about 0.2 mile. None of the routes parallel gas pipelines for a significant distance although Alternative Routes C, D, and E cross the Illinois River adjacent to a pipeline corridor containing five pipelines. Alternative Routes F and G do not parallel pipelines or transmission lines. Alternative Routes C, D, and E have the most total length along parcel ownership boundaries (49, 46, and 44 percent, respectively). Alternative Routes F and G run along parcel ownership boundaries for only 40 and 38 percent, respectively, of their length. While Alternative Routes C, D, and E parallel existing transmission lines, there is less than a 1 percent total length of parallel for each, so the difference between each route for transmission line parallel is minimal. Additionally, Alternative Route C has the shortest length, which would affect less land overall and decrease impacts due to construction. Each of the Alternative Routes require multiple crossings of existing transmission lines and existing or planned pipelines. Overall, engineering challenges associated with any Alternative Routes would be comparable, given similar numbers of lower voltage transmission line and pipeline corridors crossed. While none of the Alternative Routes parallel a significant distance of existing transmission line, Alternative Routes C, D, and E avoid crossing the Illinois River where no utilities are currently present.

178 Segment 3 Segment 3 Alternative Routes range from 93.6 miles to 99.8 miles long. Alternative Routes H and L parallel existing transmission lines for the greatest length each paralleling existing transmission lines for more than 35 miles. Alternative Routes K and O have the least amount of parallel siting to existing transmission lines, at 2.6 miles each. Routes that run along parcel boundaries for the greatest length are Alternative Route K (52.6 miles), Alternative Route O (49.3 miles), and Alternative Route I (46.7 miles). Collectively, the routes that have the greatest percentage of siting parallel to existing transmission lines and along parcel boundaries per total length are Alternative Route H (76 percent), Alternative Route L (73 percent), and Alternative Route I (70 percent). Alternative Route L has the most length of existing ROW paralleled, yet it is longer and more circuitous, creating more impact to land overall during construction. The circuity of the route results in more angles, which will require larger, lattice structures, slightly increasing land use impacts. Route K follows parcel boundaries the most; however, the total length of the route is approximately 4.9 miles longer compared to the shortest Alternative Route. However, Route K would result in lesser impacts for farmers who farm several contiguous plots of land because the route is sited to avoid division of land owned or operated by the same individual, and has fewer angles. Each of the Segment 3 Alternative Routes crosses several existing transmission lines and pipelines. Alternative Routes H and J have the most total transmission line crossings, 5 of which are of 345 kv transmission lines. Alternative Routes N and L also have 5 crossings of 345kV transmission lines. Although engineering challenges still exist when crossing any transmission line, crossing lower voltage lines is typically less of a challenge. Alternative Routes H and L parallel existing transmission for a significant distance, which could provide opportunities to use existing access roads. Segment 4 Alternative Route P is about 11 miles long and Alternative Route Q is nearly 12 miles long (Table 5-17). Alternative Route P parallels existing transmission lines for 100 percent of its length. Alternative Route Q is parallel to about 3.6 miles of existing transmission lines (31 percent) and has about 19 percent of its length sited along parcel boundaries, which is slightly more than 2 miles of its total length. The total percent of Alternative Route Q that runs parallel to existing ROW is 50 percent, half that of Alternative Route P. Both Alternative Routes cross the Kansas Hutsonville 138 kv transmission line west of Angling Road. As it exits the proposed converter site location, Alternative Route P also crosses the Casey Breed 345 kv transmission line.

179 Table Transmission and Pipeline Crossings for Alternative Routes Transmission Lines Crossed Alternative Routes Segment 1 Segment 2 Segment 3 Segment 4 A B C D E F G H I J K L M N O P Q <115 kv kv or 138 kv kv Pipelines crossed Total Crossings The accuracy and completeness of this data could only be verified at locations which pipeline markers could be observed along public roads. Further coordination with pipeline companies may be required to determine precise locations of pipelines and their associated ROW.

180 Alternative Route Q remains south of the existing 345 kv line for its entire length. Alternative Route P would result in less impact than Alternative Route Q due to a number of factors. The total length of Alternative Route P is slightly shorter and less circuitous, and following the existing ROW may allow existing access roads to be used through forested areas. In addition, Alternative Route P crosses one more 345 kv transmission line compared to Alternative Route Q Transportation Network Crossings Township and county roads are the dominant mode of transportation within the majority of the predominately rural Study Area. Major highways provide some connections between larger towns or cross through the Study Area to connect larger cities. Major transportation routes include I-55, I-57, and I-70; and U.S. Highways 40, 45, 51, 54, and 67. Also, several private and public airfields are used for municipal, agricultural, and recreational activities. The Routing Team avoided routes crossing directly over public and private airfields; however, several Alternative Routes do fall within an estimated obstruction zone. The estimated obstruction zones were calculated using the same requirements as the Federal Aviation Administration (FAA) approximated notification zone requirements (Code of Federal Regulations, Title 14, Part 77 Subpart B). Many of the larger towns and cities in the Study Area are connected by railroads, several of which are crossed by Alternative Routes in each segment. General Impacts and Best Management Practices Numerous U.S. highways, state highways, and county and local roads transect the Study Area. Highways and roadways can be spanned by the transmission line and impacts are generally minimal. During construction it may be necessary to close portions of roads to allow the stringing of the conductor over the road. Coordination with the Illinois Department of Transportation will occur for all highway crossings associated with the Project. Similarly, the crossing of rail lines results in minimal impacts, although coordination with railway operators will be necessary during construction of the railway crossings. Generalized notification zones for public and military airports and heliports are determined per FAA regulations (Code of Federal Regulations, Title 14, Part 77, Subpart B). The notification zone are designed to identify potential flight obstructions and are based on the projected height of structures and the airport runway length. Once notified of the potential obstruction (FAA form ), the FAA conducts an aeronautical analysis to determine if any adverse impacts may be created to the safe and efficient use of navigable airspace. Impacts from structures located within a notification zone can be mitigated by lighting or marking the structure or by situating the new structure adjacent to an existing obstruction (such as an existing transmission line or tree line). Similar generalized notification zone buffers were considered around verified

181 private airfields to avoid negatively impacting their operations, even though these regulations do not apply to private airfields. Alternative Route Comparison Segment 1 Both of the Alternative Routes in Segment 1 cross State Highway 96, also known as Great River Road, which is a scenic road for portions of the route in Illinois (Table 5-19). State Highway 1 runs along the bluffs at the edge of the Mississippi River floodplain and will be crossed roughly perpendicularly by each route. No public or private airfields are located close to either of the Alternative Routes in Segment 1 (Figure 5-7A). No significant impacts to transportation are expected from either of the Alternative Routes in Segment 1. Segment 2 All of the Alternative Routes in Segment 2 cross I-55 and U.S. Highways 54 and 67. Table 5-19 lists the number of times each Alternative Route crosses highways and other transportation infrastructure. Alternative Routes C, D, and E cross the most state highways (five), while Alternative Routes F and G cross four different state highways. None of the routes have more than one crossing of any individual highway. Two public airfields (Pittsfield Penstone Municipal and Zelmer Memorial Airpark) are relatively close to the Alternative Routes in Segment 2 (Figure 5-7A), although none of the Alternative Routes cross the obstruction zone of either airfield (Table 5-20). Alternative Routes D, E, F, and G cross the estimated obstruction zone of two private airstrips, Ribble Airport and Killam Flying Service in Macoupin County. The Alternative Routes are approximately 6,650 feet from the northern end of Ribble Airport runway and 5,400 feet from the northern end of the Killam Flying Service runway. Because of the distance of the Alternative Routes to the end of the runways and the presence of significant tree cover between the end of each runway and the Alternative Routes, impacts to the operation of either airfield are not anticipated. Segment 3 All of the Alternative Routes in Segment 3 cross I-57 and I-70. Table 5-19 lists the number of times U.S. highways and state highways are crossed by each Alternative Route. Alternative Routes H, J, L, and N cross the most U.S. and state highways (three crossings of U.S. highways and seven crossings of state highways), while Alternative Routes I, K, M, and O all cross three different U.S. highways and six state highways. The Alternative Routes cross five (J and K), six (H, I, N, and O), or seven (L and M) railroads.

182 Categories Public airfields (miles of FAA Notification Zones crossed) Private airfields (miles of estimated obstruction zone crossed) Railroad crossings Interstate crossings U.S. highway crossings State highway crossings Table Transportation Infrastructure Crossed by Alternative Routes Alternative Routes Segment 2 Segment 3 Segment 4 Segment 1 A B C D E F G H I J K L M N O P Q

183 Figure 5-7A. Transportation Infrastructure in Segments 1 and 2

184 Figure 5-7B. Transportation rtation Infrastructure ture in Segments e 3 and 4

185 Table Public and Private Airports in Segment 2 Alternative Route Airfield Name Ownership Runway Type Runway Length (feet) Distance from Alternative Route D, E, F, G, Ribble Airport Private Grass ,650 feet from the northern end of the runway D, E, F, G Killam Flying Service Private Grass 1, ,400 feet from the southern end of the runway 1 Runway information was not available from the FAA and was measured using aerial imagery. Orientation of Runway N S Parallel Orientation of Alternative Route from Runway N S Parallel

186 Table Public and Private Airports in Segment 3 Alternative Route Affected Airfield Name Ownership Runway Type Runway Length (feet) Distance from Alternative Route J, K, N, O Unnamed (Shelby County) Private Grass ,400 feet from the southeast end of the runway H, I, J, K, L, M, N, O Unnamed (Cumberland County) H, J, L, N Casey Municipal Airport Private Grass 1, ,350 feet from the northern end of the runway to Alternative Routes H, I, L, and M. 3,950 feet from the southern end of the runway to Alternative Public (A) Paved (B) Paved 1 Runway information was not available from the FAA and was measured using aerial imagery. (A) 3,900 (B) 2,000 Routes J, K, N, and O. 10,450 feet from the southeastern end of runway A to Alternative Routes H, J, L, N; 11,600 feet from the southern end of runway B to Alternative Routes H, J, L, N Orientation of Runway NW SE Parallel Orientation of Alternative Route from Runway N S Perpendicular (A): NE SW (B): N S Perpendicular

187 Alternative Routes H, J, L, and N cross the estimated FAA Notification Zone of one public airfield (Table 5-21). These Alternative Routes are 10,450 feet from the end of the main runway and 11,600 feet from the end of the secondary runway of the Casey Municipal Airport (Figure 5-7B). Several commercial and industrial buildings and a significant tree line are located between the end of the runways and the Alternative Routes, decreasing the likelihood that the airport s flight paths would be impacted. All Alternative Routes cross the estimated 7,500-foot estimated obstruction zone for a private, unnamed landing strip in Cumberland County. This unimproved landing strip is approximately 1,350 feet to the south of Alternative Routes H, I, L, and M. Alternative Routes J, K, N, and O are approximately 3,950 feet from the southernmost end of the grass landing strip. This landing strip is not listed on the FAA s list of certified and non-certified private-use facilities. Alternative Routes J, K, N, and O cross the estimated 7,500-foot obstruction zone for a private, unnamed landing strip north of the Village of Cowden. The grass strip runs in a northwest to southeast direction. The far southernmost end of the landing strip is approximately 6,400 feet from the Alternative Routes in a parallel direction. Because of the distance of the Alternative Routes from the runway, the parallel orientation of the routes in relation to the airstrip, and the preexisting tree cover on the runway approach, impacts to the operation of the airfield are not anticipated. This landing strip is not listed on the FAA s list of certified and non-certified private-use facilities. Segment 4 Alternative Routes P and Q in Segment 4 cross State Highway 1 north of West Union. Alternative P crosses the state highway adjacent to an existing 345 kv transmission line. There are no Interstates or U.S. highways crossed by either Alternative Route. No public or private airfields are located close to the Alternative Routes in Segment Constructability Considerations Potential engineering challenges or difficulties are important to consider when routing a transmission line. Sharp angles, excessive road and stream crossings, double-circuit structures, narrow ROW alignments, steep topography, and unnecessary length are all elements that could ultimately require extensive engineering and can lead to increases in impacts and overall cost. For example, every turn in the line requires a different, and often more expensive and generally larger, type of structure. Avoiding circuitous routes can reduce challenges in the engineering and environmental permitting phases of the Project. Grain Belt Express considered and attempted to minimize engineering challenges during the conceptual design phase.

188 Alternatives Comparison Segment 1 The Alternative Routes in Segment 1 have a similar number of angle structures (Table 5-17) and similar challenges exist for the engineering of the structures within the Mississippi River floodplain where more robust foundations may be required. Alternative Route A crosses more quickly into the more heavily forested and topographically variable bluffs than Alternative Route B. In the more forested or steeper terrain found in the bluffs there is a greater likelihood of off-row access roads. Alternative Route B has approximately half the distance of Alternative Route A in this type of terrain (3 miles to 6 miles) and could therefore require fewer off-row access roads. Segment 2 Each of the Segment 2 Alternative Routes is expected to require a minimum of 50 angled structures, aside from Alternative Route C, which will require 45. As shown in Table 5-17, Alternative Routes F and G are expected to require the most angled structures as a result of paralleling the Mississippi River through the bluffs. Alternative Route C traverses over 6 miles of abandoned mine lands while the remaining Alternative Routes will traverse no or very minimal abandoned mine land. Each of the Alternative Routes traverse a significant distance through karst topography. Alternative Routes F and G traverse slightly more steep slopes compared to Alternative Routes C, D and E as a result of traversing through the Mississippi River bluffs for a longer distance. Because Alternative Routes F and G traverse a greater distance through the bluffs, there is a greater likelihood of requiring longer off-row access roads. In addition to crossing less steep slopes, Alternative Route C crosses nearly 4 miles less forested land than the other Alternative Routes, further decreasing the likelihood of requiring off-row access roads. Segment 3 Aside from Alternative Route K, each of the Alternative Routes is expected to require at least 40 angled structures (up to 59 angled structures). Alternative Route K will require the fewest angled structures (37). None of the Alternative Routes will traverse a significant distance through areas of steep slopes. Each of the Alternative Routes will traverse a similar distance of abandoned mine lands. Alternative Routes L, M, N, and O cross adjacent to an existing surface quarry near the Village of Wenonah. Discussions with local landowners and representatives from the quarry indicated that the quarry will expand to the south, encompassing the area these Alternative Routes will traverse. Transmission line crossings of quarries are not uncommon but will require coordination with the quarry managers to ensure blasting or other extractive activities do not impact structure foundations. Alignment of those Alternative Routes directly adjacent to North 22 nd Avenue should mitigate impact on the current agricultural land use and future quarry expansion.

189 Alternative Routes H, J, L, and N cross through a congested area north of Greenup. In this area, the routes parallel an existing 345 kv transmission line, cross several roadways including I- 70 and U.S. 40 (the National Road), pass close to two cellular towers, go through higher residential density, and cross a large recreational motocross facility. None of these issues will preclude the transmission route through this area, but the combination of them decreases flexibility in adjusting the routes should engineering issues arise during construction. Impacts from access roads will likely be similar for all Alternative Routes in Segment 3. West of the Kaskaskia River the routes cross through primarily agricultural land, mostly along parcel boundaries. Off-ROW access roads through these areas will be minimal and similar across all of the Alternative Routes. East of the Kaskaskia River the northern set of Alternative Routes (H, I, L, and M) parallel existing transmission lines for significant portions of their length. Through these areas there may be opportunities to utilize existing access roads, although existing permanent access roads along the existing transmission line through agricultural areas are not common. Therefore, it is expected that a similar length of off-row access roads will be necessary for each of the Alternative Routes. Segment 4 Alternative Route P is a more direct route into the Converter Station while Alternative Route Q will require several additional angled structures to reach the site. Because Alternative Route P parallels the Casey Breed 345 kv Transmission Line for its entire route, there may be opportunities to use existing access roads. Both Alternative Routes traverse a similar distance through steep slopes. Alternative Route Q avoids some of the forested riparian areas associated with Little Creek, while Alternative Route P avoids the forested riparian corridor along the North Fork Raccoon Creek. Similar to Segment 3, paralleling existing transmission lines may provide an opportunity to utilize existing access roads; however, existing permanent access roads are not likely through the type of heavy agricultural fields crossed by Alternative Routes in Segment 4. No karst topography or abandoned mining areas are located within Segment Engineering Summary Segment I While engineering challenges between the Segment I Alternative Routes are similar, Alternative Route B is slightly preferred from an engineering perspective because it traverses a shorter distance through the Mississippi River bluffs, which results in less steep terrain and less off- ROW access roads. Paralleling roads for nearly a quarter of its total length also decreases the need for off-row access roads for Alternative Route B.

190 Segment 2 Alternative Route C is preferred from an engineering perspective because it is a shorter route that is expected to require fewer angled structures. The route crosses the least steep slopes and has the least forested area crossed, decreasing the likelihood of requiring off-row access roads as compared to the other Alternative Routes. It is the only route in Segment 2 to completely avoid estimated obstruction zones for private airfields. Segment 3 In general, the relative similarity in land use, steep slopes crossed, infrastructure crossings, and overall length indicate that engineering challenges are expected from any of the Alternative Routes in this Segment. However, Alternative Route K is the only alternative that does not cross the proposed quarry expansion near Wenonah and does not cross through the congested area north of Greenup. Alternative Route K is slightly preferred in Segment 3 from an engineering perspective. Segment 4 Engineering challenges are similar between Alternative Routes P and Q. Alternative Route P is slightly preferred from an engineering perspective because it is a slightly shorter route, requires fewer angled structures, and may be able to take advantage of existing access roads used for the adjacent transmission line.

191 6. Identification of the Proposed Route 6.1 Rationale for the Selection of the Proposed Route As stated in the introductory chapters, the goal in selecting a suitable route for the Project is to minimize impacts on the natural, cultural, and human environment while avoiding circuitous routes, extreme costs, and non-standard design requirements. However, in practice, it is not usually possible to optimally minimize all potential impacts at all times. There are often inherent tradeoffs in potential impacts to every routing decision. For example, in heavily forested study areas, a route that avoids the most developed areas would likely require the greatest amount of forest clearing, while the route that has the least impact on vegetation and wildlife habitats often impacts more residences or farm lands. Thus, an underlying goal inherent to a routing study is to reach a reasonable balance between minimizing potential impacts on one resource versus increasing the potential impacts on another. The following section presents the rationale for selection of the Proposed Route and, thus, the route that the Routing Team considered to best minimize the impacts of the Project overall. The rationale is derived from the accumulation of the routing decisions made throughout the process, the knowledge and experience of the Routing Team, comments from the public and regulatory agencies, and comparative analysis of potential impacts presented in Chapter Summary of Alternative Route Comparison Segment 1 Alternative Route A Advantages Crosses the shorter distance in the 100- and 500-year floodplain (3.2 miles) Parallels an existing transmission line (1.8 miles) Crosses fewer miles of wetlands (1.0 miles) Contains fewer acres of agricultural land within the 200-foot ROW (179 acres) Disadvantages Contains the most acres of forested land within the 200-foot ROW (110 acres) with more forest fragmentation, and potential impacts to special status bat species and timber rattlesnake potential habitats Crosses the most small parcels less than10 acres (10) Has more houses within 250 feet (2) and 500 feet (3)

192 Crosses the longer distance of steep slopes greater than 20 percent (960 feet) Passes within 1,000 feet of a cemetery (1) Alternative Route B Advantages Crosses fewer small parcels less than 10 acres (5) Contains fewer residences within 250 feet (0) and 500 feet (2) Crosses the shorter distance of steep slopes greater than 20 percent (600 feet) Disadvantages Contains fewer acres of forested land within the 200-foot ROW (74 acres) with less forest fragmentation, and impacts to special-status bat species and timber rattlesnake potential habitats Crosses the longer distance in the 100 and 500-year floodplain (4.1 miles) Crosses more miles of wetlands (1.4 miles) Contains more agricultural land within the 200-foot ROW (206 acres) Segment 2 Alternative Route C Advantages Has the shortest overall length (83.3 miles) Crosses the shortest length in the 100- or 500-year floodplain (5.0 miles) Has the fewest residences within 250 feet (1, same as D and E) and 500 feet (8) Sited the greatest distance along distinct-ownership parcel boundaries (40.5 miles) Crosses the shortest distance of karst (33.5 miles, same as D and E) Contains the fewest acres of forested land within the 200-foot ROW (450 acres) with less forest fragmentation, and potential impacts to special-status bat species and timber rattlesnake potential habitats Crosses the fewest miles of wetlands (1.2 miles) Disadvantages Crosses the shortest length of steep slopes greater than 20 percent (2,180 feet) Crosses the greatest acres of conservation opportunity areas (338 acres, same as D and E)

193 Crosses the greatest length of inactive mine areas (6.3 miles) Crosses the greatest number of small parcels less than 10 acres (35) and the greatest total number of parcels (578) Contains the most acres of agricultural land within the 200-foot ROW (1,546 acres) Alternative Route D Advantages Parallels road and railroad ROWs for the longest distance (6.8 miles, same as E) Crosses the second-shortest length of steep slopes greater than 20 percent (2,210 feet, same as E) Crosses the shortest distance of karst (33.5 miles, same as C and E) Disadvantages Crosses the greatest acres of conservation opportunity areas (338 acres, same as C and E) Crosses the greatest number of archaeological sites within 200-foot ROW (8, same as E) Crosses the most streams (215) Borders the longest distance of recreation land (2,480 feet, same as E) Alternative Route E Advantages Parallels road and railroad ROWs for the longest distance (6.8 miles, same as D) Crosses the second-shortest length of steep slopes greater than 20 percent (2,210 feet, same as D) Crosses the shortest distance of karst (33.5 miles, same as C and D) Disadvantages Has the greatest overall length (86.0 miles) Crosses the second-highest number of streams (213) Crosses the greatest acres of conservation opportunity areas (338 acres, same as C and D) Borders the longest distance of recreation land (2,480 feet, same as D) Contains the most archaeological sites within ROW (8, same as D)

194 Alternative Route F Advantages Crosses the second-fewest streams (129) Borders the second-shortest distance of recreation land (1,240 feet, same as G) Crosses the second-fewest number of small parcels (26) Crosses the fewest number of total parcels (454) Crosses no inactive mine areas (same as G) Contains the fewest archaeological sites within the 200-foot ROW (5, same as G) Disadvantages Crosses the second-longest distance in 100- and 500-year floodplain (7.1 miles) Crosses the longest length of steep slopes between 15 percent and 20 percent (9,780 feet, same as G) and greater than 20 percent (3,560 feet, same as G) Crosses the greatest distance of karst (41.9 miles, same as G) Comes within 1 mile of a site listed on the National Register (1, same as G) Alternative Route G Advantages Crosses the fewest streams (127) Borders the second-shortest distance of recreation land (1,240 feet, same as F) Crosses the fewest small parcels (25) Crosses the second-fewest total parcels (486) Disadvantages Contains the fewest acres of agricultural land within the 200-foot ROW (1,380 acres) Crosses the longest distance in 100- and 500-year floodplain (7.5 miles) Crosses the most miles of wetlands (1.5 miles) Sited the shortest distance along distinct-owner parcel boundaries (32.1 miles) Crosses the longest length of steep slopes between 15 percent and 20 percent (9,780 feet, same as F) and greater than 20 percent (3,560 feet, same as F) Crosses the greatest distance of karst (41.9 miles, same as F) Contains the most acres of forested land within the 200-foot ROW (590 acres)

195 Comes within 1 mile of a site listed on the National Register (1, same as F) Segment 3 Alternative Route H Advantages Has the shortest overall length (93.6 miles) Contains the second-fewest archaeological sites within the 200-foot ROW (1, same as K) Crosses the fewest miles of wetlands (0.9 mile) Parallels the longest distance along existing transmission lines (35.1 miles, same as L) Contains the fewest acres of forested land within the 200-foot ROW (388 acres) Disadvantages Crosses Hidden Springs State Forest (2,170 feet, same as I, L, and M) Crosses the longest distance over recreational land (2,530 feet, same as J, L, and N) Has the most residences within 250 feet (7, same as L) and 500 feet (40, same as L) Sited the second-shortest distance along distinct-owner parcel boundaries (35.2 miles) Crosses the greatest length of estimated obstruction zones for public airfields (2.8 miles, same as J, L, and N) Alternative Route I Advantages Crosses the second-fewest miles of agricultural land (69.5 miles) Has the second-shortest overall length (94.7 miles) Crosses no recreational land (same as K, M, and O) Disadvantages Crosses Hidden Springs State Forest (2,170 feet, same as H, L, and M) Crosses the second-most parcels (670) Alternative Route J Advantages Contains no archaeological sites within the 200-foot ROW Crosses no state-owned land (same as K, N, and O)

196 Contains the smallest area of water within the 200-foot ROW (2 acres, same as N) Crosses the second-shortest distance over inactive mine areas (1.3 miles, same as K) Disadvantages Parallels the second-longest distance along existing transmission lines (20.2 miles, same as N) Has the longest overall length (99.8 miles) Crosses the greatest length of estimated obstruction zones for public airfields (2.8 miles, same as H, L, and N) and private airfields (3.3 miles, same as K, N, and O) Crosses the longest distance over recreational land (2,530 feet, same as H, L, and N) Alternative Route K Advantages Crosses the fewest small parcels less than 10 acres (33) Has the fewest residences within 250 feet (0, same as O) and the second-fewest of residences within 500 feet (29) Passes within 1,000 feet of the fewest cemeteries (2, same as O) Crosses no state-owned land (same as J, N, and O) or recreational land (same as I, M, and O) Sited the longest distance along distinct-owner parcel boundaries (52.6 miles) Contains the second-fewest archaeological sites within the 200-foot ROW (1, same as H) Contains the fewest acres of residential land within the 200-foot ROW (2 acres, same as O) Crosses the second-shortest distance across inactive mine areas (1.3 miles, same as J) Disadvantages Crosses the longest distance in the 100- or 500-year floodplain (6.3 miles) Crosses the longest distance of wetlands (1.5 miles, same as O) Crosses the highest number of parcels (674) Parallels the shortest distance along existing transmission lines (2.6 miles, same as O) Contains the second-highest acreage of forested land within the 200-foot ROW (504 acres) Crosses the greatest length of estimated obstruction zones for private airfields (3.3

197 miles, same as J, N, and O) Alternative Route L Advantages Parallels the longest distance along existing transmission lines (35.1 miles, same as H) Crosses the shortest distance in the 100- or 500-year floodplain (3.7 miles) Crosses the second-shortest distance of wetlands (1.0 miles) Disadvantages Crosses Hidden Springs State Forest (2,170 feet, same as H, I, and M) Crosses the longest distance over recreational land (2,530 feet, same as H, J, and N) Crosses the highest number of small parcels less than 10 acres (42) Has the most residences within 250 feet (7, same as H) and 500 feet (40, same as H) Passes within 1,000 feet of the most cemeteries (4, same as H) Crosses the longest distance of inactive mine areas (3.7 miles, same as M) Crosses the greatest length of estimated obstruction zones for public airfields (2.8 miles, same as H, J and N) Sited the shortest distance along distinct-owner parcel boundaries (34.9 miles) Alternative Route M Advantages Second-most parallel to road/railroad ROW (3.0 miles) Crosses no recreational land (same as I, K, and O) Disadvantages Has the second-longest overall length (98.7 miles) Crosses Hidden Springs State Forest (2,170 feet, same as H, I, and L) Crosses the second-most small parcels less than 10 acres (41) and the most parcels between 10 and 30 acres (139) Crosses the longest distance of inactive mine areas crossed (3.7 miles, same as L) Contains the most archaeological sites within the 200-foot ROW (4)

198 Alternative Route N Advantages Crosses the fewest parcels (605) Crosses no state-owned land (same as J, K, and O) Crosses the shortest distance of inactive mine areas (1.2 miles, same as O) Disadvantages Parallels the second-longest distance along existing transmission lines (20.2 miles, same as J) Crosses the longest distance over recreational land (2,530 feet, same as H, J, and L) Contains the most prime farmland of statewide importance within ROW (1,295 acres) Crosses the greatest length of estimated obstruction zones for public airfields (2.8 miles, same as H, J, and L) and private airfields (3.3 miles, same as K, J, and O) Alternative Route O Advantages Passes within 1,000 feet of the fewest cemeteries (2, same as K) Crosses the shortest distance of inactive mine areas (1.2 miles, same as N) Sited the second-longest distance along distinct-owner parcel boundaries (49.3 miles) Disadvantages Contains the fewest acres of residential land within the 200-foot ROW (2 acres, same as K) Parallels the shortest distance along existing transmission lines (2.6 miles, same as K) Contains the most acres of forested land within the 200-foot ROW (509 acres) Segment 4 Alternative Route P Advantages Crosses fewer parcels (51) Parallels existing transmission lines for 100 percent of its length (11.0 miles) Crosses the shorter length of pivot irrigation systems (4,211 feet ) Contains less area of agricultural land within the 200-foot ROW (207 acres)

199 Disadvantages Crosses a longer distance of the 100- or 500-year floodplain (3.6 miles) Has more residences within 500 feet (4) Has a cemetery (1) and a church (1) within 1,000 feet Alternative Route Q Advantages Has fewer residences within 500 feet (1) Crosses the shorter distance of 100- or 500-year floodplain (3.2 miles) Does not pass within 1,000 feet of any churches or cemeteries Disadvantages Contains more area of agricultural land within the 200-foot ROW (235 acres) Crosses more parcels (59) Parallels the shorter length of existing transmission lines (3.6 miles) Crosses the greater distance of pivot irrigation systems (9,450 feet ) Parallels existing transmission lines for only 31 percent of its length and runs along distinct-owner parcel boundaries for only 19 percent of its length.

200 6.2.5 Combined Proposed Route The Routing Team recommends a combination of Alternative Routes B, C, K, and P as the Proposed Route for the Project (Figure 6-1). This combination of routes meets the overall goal of minimizing impacts on the natural, human, and historic resources, while making best use of existing divisions of land and avoiding non-standard design requirements. The Proposed Route has a total length of miles across nine counties in Illinois. Alternative Route B Selected in Segment 1 Alternative Route B follows along existing roads and field edges through the heavily cultivated floodplain of the Mississippi River, avoiding impacts to existing pivot irrigation and generally passing between fields that cannot be farmed contiguously (due to existing drainages, elevation changes, roads, etc.) Although Alternative Route A is shorter, it crosses through the middle of several fields that are farmed contiguously. These fields also have numerous large pivots with swing extensions to cover the corner of the parcel that will likely require longer spans and special design requirements to avoid. Alternative B continues into the bluffs above the cultivated floodplain to directly connect to routes in Segment 2, crossing a few large land holdings. This trajectory results in a shorter route through the heavily forested bluffs, which would result in the loss of the least amount of special-status bat habitat in an area within 10 miles of known bat hibernacula. In contrast, Alternative Route A crosses farther to the north taking a longer route to connect to the routes in Segment 2. Although a portion of this route parallels existing transmission reducing forest fragmentation effects, it clears more forest habitat due to its longer length. This includes crossing through a large area of contiguous forest identified by The Nature Conservancy as an area of concern and crossing through more potential timber rattlesnake habitat. Lastly, Alternative Route A crosses in proximity to the two more populated areas in Segment 1, and passes in proximity to more houses. In contrast, Alternative Route B approaches the bluffs farther to the south away from the more populated areas and roads, crosses fewer small parcels, and has fewer residences within both 250 feet and 500 feet. Alternative Route C Selected in Segment 2 Alternative Route C is the shortest route in the segment and follows along parcel boundaries for approximately 49 percent of the total length. It requires the least amount of forest clearing in the area between the Mississippi and Illinois Rivers (the River Hills ecosystem) an important area for habitat conservation due to its forested bluffs, greater contiguous forest areas, and potential habitat for many sensitive species including the Indiana bat and northern long-eared bat and timber rattlesnake. In fact, Alternative Route C stays along a northerly route through Segment 2, crossing through the shortest length of forested bluffs and generally crossing

201 Figure 6-1. Proposed Route and Alternate Route

202 through smaller and less forested headwater tributaries and streams that collect and drain to the south where broader more contiguous forests are found. Other Alternative Routes through this area generally followed a more southern trajectory, crossing through the forested bluffs for more than 20 miles, larger tracts of contiguous forest and streams with broader riparian forests. Alternative Route C also crosses the least amount of pasture/grassland habitat and therefore would have the least potential to impact grassland-dwelling birds. Alternative Route C crosses the Illinois River along an existing pipeline crossing, avoiding the creation of a new utility crossing location on the river. In the eastern portion of Alternative Route C, the land is more homogenously agricultural, and the route closely follows along parcel boundaries for a significant portion of its length minimizing its impact on farming operations. The southern routes through this segment are generally more circuitous, require a significant number of heavy angle structures, and commonly cross through larger contiguous cultivated lands. All of the routes except Alternative Route C cross the estimated obstruction zone for a private airstrip identified during the public meeting process and pass directly adjacent to a large Boy Scouts of America camp, Camp Bunn, near the Village of Hettick. Alternative Route C also has the fewest number of residences within 250 and 500 feet. Alternative Route C was identified as the Proposed Route portion in Segment 2 due primarily to its lower potential to impact environmentally sensitive features along its western half and more direct routing with the least amount of impact on agricultural land use and residential areas along its eastern half, as compared to the other Alternative Routes. Alternative Route K Selected in Segment 3 In the western portion of Segment 3, Alternative Route K takes a northerly route; the route is both shorter and aligned parallel to more parcel boundaries, reducing the potential impacts to agricultural land, when compared to routes farther to the south. Alternative Route K also avoids crossing through the incorporated area of Wenonah and immediately adjacent to an actively expanding rock quarry (and through an area planned for future quarry development). In the central and eastern portions of Segment 3, Alternative Route K turns to the south and follows a southern route for the rest of its length. The northern and southern routes follow different routing concepts through this portion of Segment 3. The northern routes attempt to parallel existing 138 kv and 345 kv transmission lines, while Alternative Route K follows along parcel ownership boundaries farther south. The northern route needed large diversions from maintaining the parallel alignments with existing transmission because there were numerous houses immediately adjacent to the existing line and a higher density of residences in the area. Moreover, the existing line followed a diagonal path through many large cultivated fields, which when under parallel alignment, would result in more structures in the middle of cultivated fields. In contrast to the northern routes, Alternative Route K is aligned along ownership

203 boundaries to much greater extent and would likely have a lesser impact on residential areas and agricultural lands in the middle and eastern portions of Segment 3. The northern Alternative Routes also cross the Hidden Springs State Forest parallel to the existing line along a steep banked section of Richland Creek, which would likely require significant clearing along both sides of the riparian corridor. Illinois DNR expressed concerns for this crossing, given its potential impacts on sensitive aquatic and riparian habitats, as well as the stability of the steep rocky valley sides of this stream. In contrast to the northern Alternative Routes, Alternative Route K avoids the Hidden Springs State Forest and impacts to the Richland Creek riparian corridor. Farther east, the northern Alternative Routes of Segment 3 continue along the existing 345 kv transmission line, but deviate from parallel alignments due to increased residential density causing the routes to cross through more heavily forested areas along Mule Creek, Otter Branch, and Muddy Creek limiting the benefits of parallel alignments on forest fragmentation. East of I-70, the northern Alternative Routes cross the Lincoln Trail Motosports facility; although long-term impacts to the operations of the site are likely mitigatable, the site would be impacted significantly during the construction phase of the project and potentially during future maintenance activities. The Alternative Routes in this section cross the estimated obstruction zone for the Casey Municipal Airport; likely requiring additional obstruction zone analysis to identify any potential impacts on current airport operations. In contrast, Alternative Route K crosses through similar agricultural areas, but with fewer forested riparian corridors. Over half of the length through this area runs along parcel ownership boundaries to avoid impacts on agricultural operations and has half as many residences within 250 feet compared to the northern routes. Overall, Alternative Route K follows parcel boundaries to great extent, while avoiding crossing through a planned quarry expansion, the incorporated area of Wenonah, the Hidden Springs State Forest, and the Lincoln Trail Motosports facility. It also has fewer small parcels crossed (less than 10 acres), fewer residences within 250 feet and 500 feet, no public airfield obstruction zone crossing, one National Register location within 1 mile, and the greatest percent of total length along ownership boundaries compared to the other Alternative Routes in Segment 3. Alternative Route P Selected in Segment 4 Segment 4 is roughly 11 miles in length, and includes a connection to the proposed converter station and the crossing of the Wabash River into Indiana. In the western portion of Segment 4, Alternative Route P parallels along the south side of the existing 345 kv transmission line from its connection with Alternative Route K to the proposed converter station location. Residential development along the line is relatively limited, and no diversions from the parallel

204 alignment are required to avoid individual residences. In contrast, Alternative Route Q farther to the south, only somewhat follows along parcel boundaries to avoid residences. Because Alternative Route P parallels an existing transmission line for its entire length, it would have less of an impact on forest fragmentation than Alternative Route Q. East of the proposed converter station location, the two Alternative Routes follow similar paths; however, Alternative Route P would impact existing pivot irrigation systems the least. With Alternative Route Q, one pivot would have diminished coverage and crossing four of the pivot systems would require longer than typical spans, introducing non-standard designs and increasing the costs and foundation impacts associated with larger structures. Only one pivot along Alternative P would require a longer span; therefore, Alternative Route P is preferred from both an agricultural impact and engineering point of view. Alternative Route P is selected as the Proposed Route in Segment 4 because it is parallel to an existing high-voltage transmission line for its length with no diversions and would have less impact to pivot irrigation facilities and forest fragmentation. The Proposed Route The combination of Alternative Routes B, C, K, and P comprise a Proposed Route for the Project that is reasonable and sound because: 1) the selection of the Proposed Route integrated input from government agencies, local officials, and the general public into the route development, analysis, and selection process; and 2) the Proposed Route best minimizes the overall effect of the Grain Belt Express transmission line on the natural and human environment while avoiding unreasonably circuitous routes, unreasonable costs, and special design requirements Combined Alternate Route The Routing Team recommends a combination of Alternative Routes A, G, a slightly modified L, and Q as the Alternate Route for the Project (Figure 6-1). The Alternate Route has a total length of miles across nine counties in Illinois. The Routing Team considers this route to adequately meet the overall goal of minimizing impacts on the natural, human, and historic resources, while making use of existing divisions of land, avoiding non-standard design requirements, and being completely distinct from the Proposed Route per Illinois statute. The latter of these requirements required the slight modification to Alternative Route L in Segment 3, as shown in Figure 6-1. The proposed modification shifts a small 2-mile segment of the route 0.5 mile to the east to ensure the route alignment is not coincident with any portion of the alignment of the Proposed Route. This modification follows along existing divisions of land and results in no impacts beyond those of the original alignment, ensuring consistency with the analysis presented in this study.

205 Although the Routing Team considers the Proposed Route to be the best assemblage of the Alternative Routes, it should be noted that the Alternate Route was also developed through the same methodology, integrating input from government agencies, local officials, and the general public into the route development, analysis, and selection process. Like the Proposed Route, Alternative Routes A, G, L, and Q were continually revised and refined through this process, including multiple iterative rounds of selection through the Conceptual and Potential Route development phases, engineering reviews, and comparative assessment from the Routing Team. The combination of Alternative Routes A, G, L, and Q comprise an Alternate Route for the Project that is reasonable and sound because: 1) the selection of the Alternate Route followed the same methodology as the Proposed Route, integrating input from government agencies, local officials, and the general public into the route development, analysis, and selection process; 2) the Alternate Route abides by the routing guidelines and reasonably minimizing the overall effect of the Grain Belt Express transmission line on the natural and human environment, while avoiding unreasonably circuitous routes, unreasonable costs, and special design requirements; and (3) the Alternate Route is a completely separate route from the Proposed Route with no coincident portions.

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207 7. References FERC (Federal Energy Regulatory Commission) Guidelines for the Protection of Natural, Historic, Scenic, and Recreational Values in the Design and Location of Rightsof-Ways and Transmission Facilities. Federal Power Commission Order No November 27, Heckert, J.R., and J.E. Ebinger (editors) Endangered and Threatened Species of Illinois: Status and Distribution, Volume 1 Plants. Endangered Species Protection Board, Springfield, Illinois. 161 pp. Available at: Accessed January 22, IDNR (Illinois Department of Natural Resources) Illinois Comprehensive Wildlife Conservation Plan and Strategy. Version 1.0. IDNR Integrating Multiple Taxa in a Biological Stream Rating System. August, IDNR Biological Stream Ratings. Available at: Accessed March 30, IDNR. 2015b. Conservation Opportunity Areas. Available at: px. Accessed August IDNR. 2015c. Illinois Threatened and Endangered Species by County. Illinois Natural Heritage Database as of October Available at: Accessed January 22, Illinois Environmental Protection Agency. 2014a. Illinois Integrated Water Quality Report and Section 303(d) List, 2014, Volume 1: Surface Water. Available at: Accessed January 21, Illinois Environmental Protection Agency. 2014b. Illinois Integrated Water Quality Report and Section 303(d) List, 2014, Volume 2: Groundwater. Available at: Accessed January 21, 2015.

208 Illinois State Geological Survey Physiographic Divisions of Illinois. Available at: Accessed January 14, INHS (Illinois Natural History Survey). 2015a. List of Illinois Taxa (and Number of Species). Available at: Accessed January Updated INHS. 2015b. INHS Collections Database. Available at: Accessed January 22, Mankowski, A. (editor) Endangered and Threatened Species of Illinois: Status and Distribution, Volume and 2019 Changes to the Illinois List of Endangered and Threatened Species. Illinois Endangered Species Protection Board, Springfield, Illinois. Iii + 38 pp. Available at: Accessed January 22, Nyboer, R.W. and J.E. Ebinger (editors) Endangered and Threatened Species of Illinois: Status and Distribution List of Endangered and Threatened Plant Species. Illinois Endangered Species Protection Board, Springfield, Illinois. 34 pp. Available at: Accessed January 22, Nyboer, R.W., J.R. Herkert, and J.E. Ebinger (editors) Endangered and Threatened Species of Illinois: Status and Distribution, Volume 2 Animals. Illinois Endangered Species Protection Board, Springfield, Illinois. 181 pp. Available at: Accessed January 22, USACE (U.S. Army Corps of Engineers). 2015a. Navigation Charts of the Upper Mississippi River. Available at: OVER.pdf. Accessed April 1, USACE. 2015b. National Levee Database Web Page. Available at: Accessed March 11, USDA (U.S. Department of Agriculture) Land Resource Regions and Major Land Resource Areas of the United States, the Caribbean, and the Pacific Basin. USDA Handbook 296. USDA CREP (United States Department of Agriculture, Conservation Reserve Program) Conservation Reserve Program Factsheet. Available at:

209 Accessed March 11, USDA Forest Service (United States Department of Agriculture, Forest Service) Landscape Aesthetics: A Handbook for Scenery Management. Available at: end.pdf. Accessed November 3, USDA NASS (U.S. Department of Agriculture, National Agricultural Statistics Service) National Agricultural Statistics Service Statistics by State Web Page. Available at: Accessed November 20, USDA NRCS (United States Department of Agriculture, Natural Resource Conservation Service) Available at: Accessed March USFWS (U.S. Fish and Wildlife Service). 2015a. Illinois County Distribution of Federally Listed Threatened, Endangered, Proposed, and Candidate Species. Revised December Available at: Accessed January 22, USFWS. 2015b. U.S. Fish and Wildlife Service Proposes Special Rule to Focus Protections for Northern Long-Eared Bat. Available at: Accessed February USFWS National Wetlands Inventory Illinois. U.S. Fish and Wildlife Service. USFWS Gray bat (Myotis grisescens) 5-Year Review: Summary and Evaluation. U.S. Fish and Wildlife Service Midwest Region, Columbia, Missouri Ecological Services Field Office, Columbia, MO. USFWS Indiana Bat (Myotis sodalis) Draft Recovery Plan: First Revision. U.S. Fish and Wildlife Service, Fort Snelling, MN. 258 pp. USFWS Recovery Plan for the Great Lakes Piping Plover (Charadrius melodus). Ft. Snelling, MN. USFWS Gray Bat Recovery Plan. Minneapolis, MN. 26 pp. + appendices.

210 U.S. Geological Survey National Hydrography Dataset Illinois. Woods, A.J., J.M. Omernik, C.L. Pederson, and B.C. Moran Level III and IV Ecoregions of Illinois. Available at: %20Ecoregions%20of%20Illinois%20Woods.pdf. Accessed March 5, 2015.

211 Grain Belt Express Clean Line Illinois Route Selection Study APPENDIX A: DESIGN SPECIFICATIONS AND STRUCTURE TYPES

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213 Grain Belt Express Clean Line Illinois Route Selection Study A-1

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219 Grain Belt Express Clean Line Illinois Route Selection Study APPENDIX B: ROUTING TEAM

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221 Grain Belt Express Clean Line Illinois Route Selection Study ROUTING TEAM Member Affiliation Title Specific Role Mike Skelly CLE President Project oversight Jason Thomas Wayne Galli Mark Lawlor Diana Rivera CLE CLE CLE CLE Environmental Director Adhar Johnson CLE Manager Executive Vice President, Transmission and Technical Services Director of Development Project Development Manager Ally Copple CLE Associate John Kuba CLE Manager, Environmental Affairs Environmental oversight Engineering support and oversight Siting support, public outreach, agency consultation Siting support and public outreach Siting support and public outreach and relations Siting support and public outreach Siting support, agency consultation, environmental and sensitive species Cari VanAmburg CLE Associate Public outreach support Daniel Hodges Copple CLE Associate Public outreach support Alex Landon CLE Associate Public outreach support Louisa Kinoshi CLE Associate, Communications Ty White CLE Associate GIS support Parker Lewis CLE Associate GIS support Timothy Gaul Laurie Spears LBG LBG Associate Vice President, Energy Services Environmental Planner James Puckett LBG GIS Specialist Public outreach support and graphics Project Director, siting support, agency consultation, public outreach Project Manager, siting support, agency consultation, public outreach Siting support, GIS analysis and mapping B-1

222 Grain Belt Express Clean Line Illinois Route Selection Study ROUTING TEAM Member Affiliation Title Specific Role Todd McCabe Emily Larson Brad Fine LBG LBG LBG Environmental Scientist Environmental Scientist Environmental Planner Linda Green LBG GIS Specialist Karie Kneller Chris Flannagan Mark Reasoner Camilla Deiber Shaun Lynch Laura Totten Mike Snyder Neeli Landon Phil Robertson Kelsey Rockey Kelly Cooper LBG LBG LBG LBG LBG LBG LBG LBG POWER Engineers Parris Communications Parris Communications Environmental Planner Environmental Scientist Environmental Planner Cultural Resource Specialist Cultural Resource Specialist Environmental Scientist Environmental Scientist Communications Specialist Engineer Communications Specialist Communications Specialist Siting support, public outreach, agency consultation, GIS support, sensitive species, land use Siting support and public outreach Siting support, public outreach support and logistics, engineering GIS analysis and mapping, public outreach Public outreach, support and logistics Soils and geology Visual and recreational resources Architectural resources Archaeological resources Wildlife and habitat and sensitive species Water resources Public outreach Siting support and engineering Public outreach Public outreach B-2

223 Grain Belt Express Clean Line Illinois Route Selection Study APPENDIX C: DATA SOURCES

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225 Grain Belt Express Clean Line Illinois Route Selection Study Category Definition Units Data Source Aerial Photography National Agricultural Imagery Natural Resources Hydrology Streams Water bodies Wetlands Floodplains Illinois National Agricultural Imagery Program, 2008, 2010, 2012, 2014 National Hydrography Dataset flowlines National Hydrography Dataset waterbodies National Wetlands Inventory 100 and 500- year floodplains Number of streams crossed Length of water body crossed by potential route Length of wetlands crossed by Potential Route, acres of wetland within 200-foot ROW The National Agricultural Imagery Program (NAIP) obtains aerial imagery during agricultural growing seasons. The most current imagery for the State of Illinois when the project began was taken in Imagery flown in 2010, 2012, and 2014 was used once it became available. Imagery is collected at the spatial resolution of 1 square meter and with the spectral resolution as natural color. A statewide subset of the National Hydrography Dataset (NHD) model version 2 was downloaded from the United States Geological Survey (USGS). Feature classes used for calculations included canal/ditch, stream/river (intermittent and perennial), artificial path, and any named features. A member of the Routing Team verified each stream/river crossing point using 2014 NAIP imagery. A statewide subset of the NHD model version 2 was downloaded from USGS. National Wetland Inventory (NWI) data were downloaded from the U.S. Fish and Wildlife Service's (USFWS) website. The Federal Emergency Management Agency (FEMA) provides a digital version of its National Flood Hazard Layer on DVDs. Floodplain data provided by the Illinois Geospatial Data Clearinghouse was used to approximate the length of floodplains crossed by the Potential Routes. C-1

226 Grain Belt Express Clean Line Illinois Route Selection Study Category Definition Units Data Source Protected and Public Lands Public and Conservation Lands Sensitive Species and Habitat Indiana Bat and Long-Eared Bat Habitat Illinois Natural Areas Inventory, Threatened and Endangered Species, Illinois Nature Preserves Commission sites Important Bird Areas Local, private, state, and federally owned lands Potential habitat crossed by route Length of public/conservation land crossed Miles This data layer represents features from a wide variety of sources, including the USGS Protected Areas Database (PADUS v1.2); U.S. Army Corps of Engineers; National Resource Conservation Service (NRCS); USFWS; U.S. Forest Service; the Nature Conservancy; National Conservation Easement Database; Illinois Department of Natural Resources (IDNR); Illinois Parks and Recreation; Illinois Nature Preserve Commission; Illinois State Geological Survey; Missouri Department of Natural Resources; Missouri Department of Conservation; Missouri Spatial Data Information service, Indiana Department of Natural Resources; Kansas Department of Wildlife, Parks, and Tourism; Kansas Data Access and Support Center; Kansas Parks and Recreation Association; and many counties and municipalities. Where possible, the boundaries of these protected areas have been edited to match parcel boundaries provided by the counties in the Study Area. USFWS publish a list of federally listed threatened, endangered, proposed, and candidate species by county for Illinois. Because all Study Area counties are listed as potential habitat for the Indiana bat and the long-eared bat, habitat for these species was calculated using forest and forested riparian areas as determined by the Photo- Interpreted Land Cover dataset. IDNR provided shapefiles of threatened/endangered species, Illinois Natural Areas Inventory sites, and Illinois Nature Preserves Commission sites. The Nature Conservancy Illinois Chapter provided data showing areas identified as Important Bird Areas in Illinois. Important Bird Areas provide crucial habitat for species of conservation concern and avian species vulnerable due to their limited range or high congregation density. C-2

227 Grain Belt Express Clean Line Illinois Route Selection Study Category Definition Units Data Source Soils and Land Use Karst Miles crossed National Land Cover Database Land Cover Steep Slopes Slopes > 20% Feet crossed Human Environment Residences Schools, Churches, Cemeteries Parcels Residences within 250, 500, and 1,000 feet Features within 1,000 feet of route Tax parcel boundaries Counts Counts Number of parcels crossed Household Density Miles crossed Data depicting regions of karst topography were acquired from USGS (via the National Atlas Map). The National Land Cover Database 2006 (NLCD 2006) compiled by the Multi- Resolution Land Characteristics (MRLC) Consortium (including USGS, Environmental Protection Agency, U.S. Forest Service, National Oceanographic and Atmospheric Association, National Aeronautics and Space Administration, Bureau of Land Management, National Park Service, NRCS, and USFWS). NLCD 2006 products include 16 classes of land cover from Landsat satellite imagery. Slopes (in percent) were derived from a digital elevation model (DEM) consisting of terrain elevations for ground positions at regularly spaced horizontal intervals (10 meters). The data used for this analysis was derived from the National Elevation Dataset (NED) prepared by USGS. Residences were digitized using high resolution aerial image interpretation as well as field reconnaissance. Aerial imagery provided by the National Agricultural Imagery Program (2009, 2010, 2012, and 2014). The locations of churches, schools, and cemeteries were derived from the USGS Geographic Names Information System (GNIS) and augmented through high resolution aerial photo interpretation, field reconnaissance, and public outreach efforts. The GNIS database serves as the federal government's repository of information regarding feature name spellings and applications for features in United States and its territories. The names listed in the inventory are often published on federal maps, charts, and in other documents and have been used in emergency preparedness planning, site-selection and analysis, genealogical and historical research, and transportation routing. Through field reconnaissance, the Routing Team recorded local schools, churches, and cemeteries to augment and verify this data layer. The routing team contacted counties in the Study Area (Pike, Scott, Greene, Macoupin, Montgomery, Christian, Shelby, Cumberland, and Clark) and purchased parcel data throughout Purchased parcel data included digital files identifying parcel boundaries and requested parcel owner name, mailing address, parcel address (if available), parcel identification number, and legal description. Household density was derived at the census block level from census population data obtained from the U.S. Census Bureau (2010). C-3

228 Grain Belt Express Clean Line Illinois Route Selection Study Category Definition Units Data Source Pivot Irrigation Systems Energy Infrastructure Transmission Lines Oil and Gas Pipelines Pivots impacted Counts Oil and Gas Wells Counts Transportation Major Roads Airport and Heliport Notification Zones Interstates, U.S. Highways, State Highways Airport points and Federal Aviation Administration Notification Zone Length parallel to existing transmission lines. Count of existing transmission lines crossed. Length parallel to existing gas line corridors. Number of each road type crossed Length of route within Federal Aviation Administration Notification Zone Pivot irrigation systems were digitized using high resolution aerial image interpretation. Members of the public were also encouraged to provide information about existing or planned pivot irrigation systems on their land, and this data aided in digitizing and verifying pivot locations. A pivot is considered potentially impacted when a potential route crosses more than 1,500 feet of irrigated area in a single span. Information on existing transmission lines was collected from Platts Transmission Lines geospatial data layer. The information was augmented through aerial photo interpretation and field review. Major natural gas and oil pipeline in formation was obtained through the EV Energy Map of North America. Spatial accuracy of the data was augmented through field review of pipeline line corridors, and pipeline ownership information was improved by comparison with the National Pipeline Mapping System online viewer. The Illinois State Geological Survey, Prairie Research Institute maintains a list of permitted oils and gas well information within the State of Illinois. Major roads data was prepared by the Environmental Systems Research Institute (ESRI), (2012) Redlands, California, USA. The location of airports and heliports was gathered from Federal Aviation Administration databases, aerial photograph interpretation, field reconnaissance, public input, and navigational charts. An approximation of the air navigation obstruction zone was developed based on the Code of Federal Regulations (CFR) Title 14 Part 77, (Aeronautics and Space, Objects affecting navigable airspace). This approximation was calculated based on aerial interpretation of runway length, the average height of the proposed transmission towers, and approach zone formulas for airports and heliports in the CFR. Note: this is a rough approximation performed based on aerial photo interpretation without the inclusion of topographic effects or precise knowledge of runway length. C-4

229 Grain Belt Express Clean Line Illinois Route Selection Study Category Definition Units Data Source Recreation Recreation Trails Scenic Byways Crossings Historic Resources Historic and Archaeological Sites Sites within ¼ mile, ½ mile, and 1 mile Recreational trails were identified using various resources such as state park maps from IDNR. Information and driving directions from the National Scenic Byways Program enabled mapping of scenic and historic byways in Missouri, Illinois, and Indiana. The Illinois State Historic Preservation Office provided shapefiles showing locations of sites and districts listed on the National Register of Historic Places and a geodatabase with spatial and tabular data for archaeological sites across the state. C-5

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231 Grain Belt Express Clean Line Illinois Route Selection Study APPENDIX D: FEDERAL AND STATE AGENCY COORDINATION

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233 March 23, 2012 Steve Chard Land & Water Resources Agriculture, Department of 801 Sangamon Ave, P.O. Box AG BLDG FL 001 Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Chard: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. We would also like to discuss implementation of an Agricultural Impact Mitigation Agreement between Clean Line and the Illinois Department of Agriculture. Clean Line would like to adopt and adhere to an agreement to help minimize impacts to agricultural lands. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at

234 or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Todd McCabe, The Louis Berger Group

235 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

236 April 25, 2012 Scherrie V. Giamanco, State Executive Director Illinois State Farm Service Agency 3500 Wabash Ave Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Ms. Giamanco: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We have contacted and are in communication with Steve Chard, Illinois Department of Agriculture and the Farm Bureau in developing an Agricultural Impact Mitigation Agreement. We would like to request any information that you may have available and give you an opportunity to comment and provide input on developing proposed routes as well. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

237 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Todd McCabe, The Louis Berger Group

238 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

239 March 23, 2012 Marc Miller, Director Illinois Department of Natural Resources One Natural Resource Way Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Miller: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

240 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Todd McCabe, The Louis Berger Group

241 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

242 October 16, 2013 Karen Miller, Section Manager Illinois Department of Natural Resources One Natural Resource Way Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mrs. Miller: Per our previous correspondence on March 23 rd, 2012, Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from Kansas to Missouri, Illinois, and states farther east. The estimated length of the transmission line will be +/- 700 miles. A Proposed Route has been presented in Kansas and a network of route alternatives are being studied in Missouri. Clean Line Energy is now in the process of selecting a route in Missouri which will include identification of a Mississippi River crossing and entry point into Illinois. We will be proposing this route in a formal application to the Missouri Public Service Commission early next year. We continue to coordinate with state and federal agencies for input on our route development efforts. As per your conversation with Todd McCabe following our March 23 rd letter, we are now looking for direct input from the IDNR concerning our specific Mississippi River crossing locations. We would like to set up a meeting to review the included material, and seek information from Illinois DNR on potential conflicts with existing DNR facilities, conservation projects, and threatened and endangered species concerns across the Mississippi River floodplain and beyond. We look forward to working with you throughout the route development and permitting process, and will contact you shortly to discuss potential meeting times and locations. For general project information, please visit the project website at or

243 Sincerely, Mark Lawlor Director, Development Clean Line Energy Partners cell tel Attachments: 1. Mississippi River Crossing Maps Cc: Marc Miller, Director Todd Rettig, Acting Director, Office of Reality and Environmental Planning Rick Pietruszka, Office of Realty and Environmental Planning John Kuba, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Todd McCabe, The Louis Berger Group

244 Illinois Counties within the Study Area Adams Calhoun Christian Clark Crawford Cumberland Greene Macoupin Montgomery Morgan Pike Sangamon Scott Shelby

245 GRAIN BELT EXPRESS CLEAN LINE Responses to Illinois Department of Natural Resources Questions (K. Shank dated 10/28/2014) Regarding the Grain Belt Express Project Can you provide me the technical specifications for a typical support structure, as well as for the corner structures? Please see the attached diagram of the typical support structures. Structure types may vary depending on various environmental or engineering conditions; however, at this time we anticipate the monopole structure/foundation will be the preferred structure type in Illinois. Please confirm that the r-o-w needs to be 120 feet either side of the lines. Is that true where an existing line is on one side, as well? The ROW width will be approximately 150 to 200 feet wide in total, or 75 to 100 feet on either side of the center line; however, the ROW width may vary in some instances where environmental or engineering factors dictate greater span lengths which may result in increased ROW widths (ex. large river crossings). The ROW width would not change where the project parallels existing infrastructure, such as along existing transmission lines, pipelines, or roads. What is the minimum ground clearance for the transmission line? The minimum ground clearance for the project is 34 feet. Can your engineers provide me with the strength of the magnetic field at ground level directly beneath the line? Is this similar or different from that to be experienced beneath an AC line? The strength of the magnetic field directly beneath the line at ground level would vary depending on the type of structures that are used for the final design and the amount of current flow that is on the line at a given point in time. For instance, the magnetic field for a lattice tower would be approximately 344 mg based on an average load and approximately 574 mg during peak load. The magnetic field associated with monopole structure would be approximately 338 mg based on an average load and approximately 564 mg during peak load. The magnetic field associated with DC lines may differ from those produced by the AC lines based on a variety of factors such as line height, conductor separation, current flow, and phasing configuration of the AC lines; however, generally speaking, the magnetic field intensity of the DC lines is consistent with the intensity of a comparable AC line as the magnetic field is dictated by current. Is there a risk of induction of current in potential conductors in proximity to the line? Since DC electricity does not vary over time and is static, the electric and magnetic fields from DC lines do not induce currents and voltages. Are there potential restrictions on land management activities in the right-of-way? For example, growing trees is obviously out of the question. 1

246 Clean Line must comply with the National Electrical Safety Code to ensure the safety of the general public and the North American Electric Reliability Corporation standards to ensure the reliable operation of the project. As a result, there are restrictions on the planting of certain trees that are at or will grow to a certain height underneath the transmission line. Crops and vegetation less than 10 feet tall may be grown safely under the power lines. Permanent structures or buildings cannot be constructed within the ROW. What about the use of prescribed fire as a land management tool? When located near or adjacent to a prescribed burn unit, the location of the transmission line and structures should be identified as a potential hazard in the prescribed burn plan and appropriate precautions should be implemented. It is recommend that the local Natural Resource Conservation Service burn specialist, Prescribed Burn Association, or other qualified person be contacted to review and provide guidance prior to implementation of controlled burns near or adjacent to any electric transmission lines. Will herbicides be routinely used in vegetation management? Grain Belt will develop a Transmission Vegetation Management Plan (TVMP) that outlines the specific vegetation management objectives and appropriate treatment types that Clean Line will employ during operations and maintenance of the project. This plan, to be filed with the North American Electric Reliability Corporation (NERC), will describe how Clean Line will conduct work on its ROW to prevent outages due to vegetation encroachment. As part of the TVMP, Grain Belt is currently considering an Integrated Vegetation Management approach to ROW maintenance. By following the principles of IVM, Clean Line can choose control methods or treatment types, including selective herbicide application, after considering the environmental impacts and anticipated effectiveness of the proposed treatment, along with the site characteristics, economics, surrounding land use and ecological community compatibility, and other sensitivities. 2

247 March 23, 2012 Bill Frey, Interim Director Illinois Department of Transportation, Division of Highways 2300 S. Dirksen Pkwy FL 002 RM 215 Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Frey: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

248 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Omer Osman, Illinois Dept. of Transportation Roger Driskell, Illinois Dept. of Transportation Todd McCabe, The Louis Berger Group

249 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

250 March 23, 2012 Roger Driskell Illinois Department of Transportation, Division of Highways 126 E. Ash FL 002 Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Driskell: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

251 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Bill Frey, Illinois Dept. of Transportation Omer Osman, Illinois Dept. of Transportation Todd McCabe, The Louis Berger Group

252 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

253 March 23, 2012 Omer Osman Illinois Department of Transportation, Division of Highways 1102 Eastport Plz Dr. Collinsville, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Osman: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

254 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Bill Frey, Illinois Dept. of Transportation Roger Driskell, Illinois Dept. of Transportation Todd McCabe, The Louis Berger Group

255 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

256 March 23, 2012 Dan Heacock, Facility Evaluation Unit Manager Bureau of Water DWPC Permit Section # North Grand Avenue East P.O. Box Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Heacock: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We would like to request any information that you may have available and give you an opportunity to comment and provide input on developing proposed routes. This coordination will be the first of many opportunities for agencies to participate in the review of this Project. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

257 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Todd McCabe, The Louis Berger Group

258 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

259 March 23, 2012 Anne Haaker, Deputy State Historic Preservation Officer Preservation Services #1 Capitol Plaza Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Ms. Haaker: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

260 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Todd McCabe, The Louis Berger Group

261 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

262 January 13, 2015 Anne Haaker, Deputy State Historic Preservation Officer Preservation Services #1 Capitol Plaza Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Ms. Haaker: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The proposed Project will begin with a converter station in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 750 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project study area has been refined and potential routes have been developed. The attached map shows the potential route network being evaluated in Illinois. Included are architectural sites identified using the Illinois Historic Preservation Agency, Historic and Architectural Resources Geographic Information System (HARGIS). We respectfully would like to request additional information regarding archaeological sites and other culturally sensitive areas. Any information obtained on archaeological sites will not be made publicly available and will be used solely for the purpose of refining the potential route network and avoiding cultural resources, where possible. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

263 Sincerely, Mark Lawlor Director, Development Clean Line Energy Partners Work: Cell: Attachments: 1. Project Overview Map Cc: John Kuba, Clean Line Energy Partners Todd McCabe, Louis Berger

264

265 March 23, 2012 Wayne Hannel, Regulatory Project Manager U.S. Army Corps of Engineers Rock Island District Clock Tower Building P.O. Box 2004 Springfield, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. Hannel: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process.

266 For general project information, please visit the project website at or Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Greg McKay, USACE Louisville District Todd McCabe, The Louis Berger Group

267 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

268 March 23, 2012 Greg McKay, Chief North Section Regulatory Branch U.S. Army Corps of Engineers Louisville District P.O. Box 59 Louisville, Kentucky Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Mr. McKay: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process.

269 For general project information, please visit the project website at or Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Wayne Hannel, USACE Rock Island District Todd McCabe, The Louis Berger Group

270 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne Indiana Counties within the Study Area Sullivan

271 July 8, 2013 U.S. Army Corps of Engineers Rock Island District Attn: Ms. Donna M. Jones, Regulatory Branch Clock Tower Building P.O. Box 2004 Rock Island, IL Re: Clean Line Energy s Grain Belt Express Transmission Project - Mississippi River Potential Crossings Dear Ms. Jones, Clean Line Energy Partners LLC (Clean Line) is proposing to develop, construct, and operate the Grain Belt Express Clean Line Transmission Project (Project). Clean Line is a privatelyowned company focused on developing high voltage direct current (HVDC) transmission lines that would connect the best renewable energy resource regions to communities and cities that have limited access to renewable energy. The proposed Project will be capable of moving up to 3,500 megawatts (MW) of renewable energy from the wind-rich region of southwestern Kansas to southeastern Missouri and markets farther east. The Louis Berger Group, Inc. (Berger) developed a potential route network for the proposed Project from the Spearville Substation in Ford County, Kansas to the Sullivan Substation in Sullivan County, Indiana. Potential routes have been developed through a process that has taken into account data analysis and field reconnaissance. In mid-july, Clean Line and Berger will be presenting these Potential Routes to the public at 12 Open Houses that will be held throughout the state of Missouri. At this time, there are 5 potential routes to cross the Mississippi River. On June 25, 2013, Berger and Clean Line held an online meeting with the U.S. Army Corps of Engineers Rock Island District to discuss the project and give an update on the current activities. In response to that meeting, Berger is submitting this letter along with maps of each crossing and shape files. We are requesting a preliminary review of each of the crossings by the Corps to help identify any information that will be helpful in further refining the crossings. Below is a brief summary of each of the potential routes. Marion County (MO)/Adams County (IL) River Mile Marker (Figures 1 and 1a) The potential route in Marion and Adams counties is the northern most crossing of the Mississippi River. The width of the river is approximately 7,000 feet (ft.) but, could be spanned with a structure on an island. The route would cross over the South River Drainage District in Marion County and the Sny Island Levee and Drainage District in Adams County. Land adjacent to the river is flat with marginal relief. Ralls County (MO)/Pike County (IL) River Mile Marker (Figures 2 and 2a) The potential route would cross at one of the more narrow points along the river. The width of the river is approximately 4,500 ft. The topography is hilly to steep on the Missouri side

272 becoming flat, cultivated land on the Illinois side of the river. The potential route would cross the Sny Island Levee and Drainage District in Pike County. Ralls County (MO)/Pike County (IL) River Mile Marker (Figures 3 and 3a) The potential route crosses the Mississippi River near mile marker 300, just north of the Edward Anderson Conservation Area. The width of the river is approximately 4,000 ft. Land adjacent to the river is flat with marginal relief on the Illinois side. In Missouri, land is hilly too steep with forest cover. Pike County (MO)/Pike County (IL) River Mile Marker (Figures 4 and 4a) The potential route parallels an existing natural gas line right-of-way crossing the Mississippi River. Topography on the Missouri side is hilly to step with residential development to the north and south. On the Illinois side, land adjacent to the river is flat, cultivated land. The width of the river is about 3,800 ft. South of the crossing is the town of Louisiana and the Upper Mississippi Conservation Area Angle Island is located to the north. In addition, there are several gas lines passing through the area. Pike County (MO)/Pike County (IL) River Mile Marker (Figures 5 and 5a) The potential route parallels an existing transmission line before diverting around a substation to cross over the Mississippi River on the Missouri side. The width of the river is approximately 9,800 ft. Crossing the river at this location would likely involve a structure on the island that is part of the Upper Mississippi Conservation Area. The potential route would cross over the Sny Island Levee and Drainage District and the Mark Twain National Wildlife Refuge, a private inholding. At this time, the proposed route has not been identified. Clean Line and Berger are requesting input from the Army Corps of Engineer on the five potential crossings described above. We would like to set up a meeting with you in the next few weeks to review the crossings and get your feedback. Please let me know if you have additional questions or would like additional information on these potential river crossings. Sincerely, Tim Gaul Louis Berger Group Associate Vice President, Energy Services Office: Mobile:

273 McCabe, Michael From: Sent: To: Cc: Subject: Attachments: Jones, Donna M MVR <Donna.M.Jones@usace.army.mil> Friday, August 02, :50 PM McCabe, Michael Hannel, Wayne MVR; Taylor, Freddie L MVR; Lundh, Joseph S MVR; Swenson, Gary V MVR; St. Louis, Paul F MVR; Jones, Sarah B MVR; Manar, Katy MVS; Brown, Jennifer MVS Grain Belt Clean Line (UNCLASSIFIED) RE: Grain Belt Express - Mississippi River Crossings 2 of 3 (UNCLASSIFIED); RE: Transmission line crossing - Grain Belt Clean Line Project 1 of 3 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Mike Here are the comments for your proposed crossing alignments within our District. It appears there may be some land use designation conflicts for the crossings at river miles 303 and 313. Please take these comments into consideration as you continue to evaluate your river crossing alternatives. Also, please remember we will also have to get a clearance from the Emergency Management folks. They are going to have to approve the clearances of the line and structures above/around the levee. The other river crossings are within the St. Louis District's river jurisdiction. They should be providing you comments for the other crossing alternatives under consideration. Let me know if there are additional questions regarding our comments. Donna M. Jones, P.E. Chief, Enforcement Section Regulatory Branch Rock Island District Corps of Engineers 309/ In order to assist us in improving our service to you, please complete the survey found at Classification: UNCLASSIFIED Caveats: NONE 1

274 McCabe, Michael From: Sent: To: Cc: Subject: Lundh, Joseph S MVR <Joseph.S.Lundh@usace.army.mil> Friday, August 02, :01 PM Jones, Donna M MVR Swenson, Gary V MVR; Nelson, Jeffrey E MVR; Knoble, John F MVR RE: Grain Belt Express - Mississippi River Crossings 2 of 3 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Donna The proposed crossing at river mile 313 crosses federal fee title acquired for the Corps of Engineers 9 foot channel project. This includes the majority of the lands and islands on the Illinois side of the channel west of the levee. These federal lands are leased to the Fish and Wildlife Service (FWS) for management whom have in turn leased the lands to the State of Illinois. Both agencies should be contacted for any continued consideration of this crossing. It also appears to cross tract IIs 16 in Pool 22 which is designated as a Natural Area according to our Land Use Allocation Plan. Constructing a power line crossing on this tract may be incongruent with its designated use and should be further reviewed by District staff. Timber rights are maintained by the Corps on these lands and clearing would require compensation/mitigation. Further consideration should include coordination with District staff on cultural resource and environmental compliance. The proposed crossing at river mile 303 also crosses federal (Corps) fee title. Some of these lands are again leased to the FWS and third party leased to Illinois. The land use designation is Wildlife Management/Reserve Forest. Both agencies should also be contacted for any continued consideration of this crossing. Timber rights are maintained by the Corps on these lands and clearing would require compensation/mitigation. Further consideration should include coordination with District staff on cultural resource and environmental compliance. The proposed crossing at river mile 300 does not appear to cross federal fee title. I will defer to the St Louis District for further comments on this and the other two crossings. Thanks for the opportunity to comment. Joseph Lundh Supervisory Natural Resource Specialist US Army Corps of Engineers Mississippi River Project PO Box 534 Pleasant Valley, IA Joseph.s.lundh@usace.army.mil Original Message From: Jones, Donna M MVR Sent: Friday, July 12, :50 AM To: Swenson, Gary V MVR; Lundh, Joseph S MVR; Fiscus, Timothy A MVR; Jones, Sarah B MVR; St. Louis, Paul F MVR Cc: Hannel, Wayne MVR Subject: FW: Grain Belt Express Mississippi River Crossings 2 of 3 (UNCLASSIFIED) Classification: UNCLASSIFIED 1

275 2 Caveats: NONE Donna M. Jones, P.E. Chief, Enforcement Section Regulatory Branch Rock Island District Corps of Engineers 309/ In order to assist us in improving our service to you, please complete the survey found at Original Message From: McCabe, Michael Sent: Monday, July 08, :17 PM To: Jones, Donna M MVR Subject: RE: Grain Belt Express Mississippi River Crossings See attached aerial maps. From: McCabe, Michael Sent: Monday, July 08, :15 PM To: donna.m.jones@usace.army.mil Subject: Grain Belt Express Mississippi River Crossings Ms. Jones, A copy of the attached letter and aerial and topographic maps were mailed to you today. I've also attached a shape file of the proposed river crossing locations in coordinate system North American Equidistant Conic. Copies of the aerial and topographic maps will be sent in separate s. If you have any questions, please let me know. Todd McCabe

276 Environmental Scientist (816) Classification: UNCLASSIFIED Caveats: NONE Classification: UNCLASSIFIED Caveats: NONE 3

277 McCabe, Michael From: Sent: To: Cc: Subject: Taylor, Freddie L MVR <Freddie.L.Taylor@usace.army.mil> Monday, July 22, :15 PM Lundh, Joseph S MVR; Jones, Donna M MVR Deutsch, Charlie MVS; VanOpdorp, Debra J MVR RE: Transmission line crossing - Grain Belt Clean Line Project 1 of 3 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Donna, CEMVR RE M has reviewed the river crossings for the subject project, and we concur with Joe Lundh's statement below that three of the crossings (Figures 3, 4, and 5) are located within the St. Louis District. However, both Figures 1 (RM ) and 2 (RM ) are located within the Rock Island District; and both crossings include Federal land on both the Missouri and Illinois shorelines. Both crossings also traverse an island, which are federally owned as well. Utilization of either of these sites would require future real estate coordination and eventual issuance of Federal authorization. Please let me know if you have any additional questions regarding this matter. V/R, Freddie L. Taylor Realty Specialist, Management and Disposal Section MVD Regional Real Estate Division North U.S. Army Corps of Engineers Clock Tower Building P.O. Box 2004 Rock Island, Illinois Original Message From: Lundh, Joseph S MVR Sent: Wednesday, July 17, :55 PM To: Jones, Donna M MVR; Taylor, Freddie L MVR Cc: Deutsch, Charlie MVS; VanOpdorp, Debra J MVR Subject: FW: Transmission line crossing Grain Belt Clean Line Project 1 of 3 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Donna I will send you some comments on these alternate crossings for this utility. Though three of the potential crossings are in the St Louis District. As such, I've included Charlie Deutsch with the River's Project Office. Freddie Likely Tim forwarded you a copy of the ...so sorry for the duplicate. The potential crossing at RM 303 goes over an island that they don't list as federal land. It appears to me that it may be federal land as we own the Illinois shoreline and it accreted to Pool 22 IIS 2 which we acquired. We may be interested in some further digging if that is the one that gets selected. Thanks, 1

278 2 Joseph Lundh Supervisory Natural Resource Specialist US Army Corps of Engineers Mississippi River Project PO Box 534 Pleasant Valley, IA Original Message From: Jones, Donna M MVR Sent: Friday, July 12, :48 AM To: Swenson, Gary V MVR; Lundh, Joseph S MVR; Fiscus, Timothy A MVR; Jones, Sarah B MVR; St. Louis, Paul F MVR Cc: Hannel, Wayne MVR Subject: Transmission line crossing Grain Belt Clean Line Project 1 of 3 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE I will be forwarding a set of 3 s from Grain Belt Clean Line. There is an additional transmission line crossing proposed in the Southern portion of the District over the Mississippi River. Grain Belt Clean Line has reduced their alternatives to the 5 locations outlined in the s. Please provide comments concerning these crossings by COB 22 July Donna M. Jones, P.E. Chief, Enforcement Section Regulatory Branch Rock Island District Corps of Engineers 309/ In order to assist us in improving our service to you, please complete the survey found at Classification: UNCLASSIFIED Caveats: NONE Classification: UNCLASSIFIED Caveats: NONE Classification: UNCLASSIFIED Caveats: NONE

279 July 8, 2013 U.S. Army Corps of Engineers St. Louis District Attn: Ms. Jennifer Brown 1222 Spruce St. St. Louis, MO Re: Clean Line Energy s Grain Belt Express Transmission Project - Mississippi River Potential Crossings Dear Ms. Brown, Clean Line Energy Partners LLC (Clean Line) is proposing to develop, construct, and operate the Grain Belt Express Clean Line Transmission Project (Project). Clean Line is a privatelyowned company focused on developing high voltage direct current (HVDC) transmission lines that would connect the best renewable energy resource regions to communities and cities that have limited access to renewable energy. The proposed Project will be capable of moving up to 3,500 megawatts (MW) of renewable energy from the wind-rich region of southwestern Kansas to southeastern Missouri and markets farther east. The Louis Berger Group, Inc. (Berger) developed a potential route network for the proposed Project from the Spearville Substation in Ford County, Kansas to the Sullivan Substation in Sullivan County, Indiana. Potential routes have been developed through a process that has taken into account data analysis and field reconnaissance. In mid-july, Clean Line and Berger will be presenting these Potential Routes to the public at 12 Open Houses that will be held throughout the state of Missouri. At this time, there are 5 potential routes to cross the Mississippi River. On June 26, 2013, Berger and Clean Line held an online meeting with the U.S. Army Corps of Engineers St. Louis District to discuss the project and give an update on the current activities. In response to that meeting, Berger is submitting this letter along with maps of each crossing and shape files. We are requesting a preliminary review of each of the crossings by the Corps to help identify any information that will be helpful in further refining the crossings. Below is a brief summary of each of the potential routes. Marion County (MO)/Adams County (IL) River Mile Marker (Figures 1 and 1a) The potential route in Marion and Adams counties is the northern most crossing of the Mississippi River. The width of the river is approximately 7,000 feet (ft.) but, could be spanned with a structure on an island. The route would cross over the South River Drainage District in Marion County and the Sny Island Levee and Drainage District in Adams County. Land adjacent to the river is flat with marginal relief. Ralls County (MO)/Pike County (IL) River Mile Marker (Figures 2 and 2a) The potential route would cross at one of the more narrow points along the river. The width of the river is approximately 4,500 ft. The topography is hilly to steep on the Missouri side becoming flat, cultivated land on the Illinois side of the river. The potential route would cross the Sny Island Levee and Drainage District in Pike County.

280 Ralls County (MO)/Pike County (IL) River Mile Marker (Figures 3 and 3a) The potential route crosses the Mississippi River near mile marker 300, just north of the Edward Anderson Conservation Area. The width of the river is approximately 4,000 ft. Land adjacent to the river is flat with marginal relief on the Illinois side. In Missouri, land is hilly too steep with forest cover. Pike County (MO)/Pike County (IL) River Mile Marker (Figures 4 and 4a) The potential route parallels an existing natural gas line right-of-way crossing the Mississippi River. Topography on the Missouri side is hilly to step with residential development to the north and south. On the Illinois side, land adjacent to the river is flat, cultivated land. The width of the river is about 3,800 ft. South of the crossing is the town of Louisiana and the Upper Mississippi Conservation Area Angle Island is located to the north. In addition, there are several gas lines passing through the area. Pike County (MO)/Pike County (IL) River Mile Marker (Figures 5 and 5a) The potential route parallels an existing transmission line before diverting around a substation to cross over the Mississippi River on the Missouri side. The width of the river is approximately 9,800 ft. Crossing the river at this location would likely involve a structure on the island that is part of the Upper Mississippi Conservation Area. The potential route would cross over the Sny Island Levee and Drainage District and the Mark Twain National Wildlife Refuge, a private inholding. At this time, the proposed route has not been identified. Clean Line and Berger are requesting input from the Army Corps of Engineer on the five potential crossings described above. We would like to set up a meeting with you in the next few weeks to review the crossings and get your feedback. Please let me know if you have additional questions or would like additional information on these potential river crossings. Sincerely, Tim Gaul Louis Berger Group Associate Vice President, Energy Services Office: Mobile:

281 March 23, 2012 Joyce Collins, Asst. Field Supervisor Marion Ecological Services Sub-Office U.S. Fish and Wildlife Service 8588 Route 148 Marion, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Ms. Collins: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

282 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Jody Millar, U.S. Fish and Wildlife Service Todd McCabe, The Louis Berger Group

283 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

284 March 23, 2012 Jody Millar, Asst. Office Supervisor Rock Island Ecological Services Field Office U.S. Fish and Wildlife Service th Avenue Moline, Illinois Re: Proposed Grain Belt Express Clean Line Transmission Project Dear Ms. Millar: Clean Line Energy Partners LLC (Clean Line) is actively developing and planning construction of a +/- 600 kv high-voltage direct current (HVDC) transmission line project known as the Grain Belt Express Clean Line (Project). The proposed Project is designed to move up to 3,500 megawatts (MW) of wind-generated electricity from the wind-rich region of southwestern Kansas to Missouri, Illinois, Indiana and markets farther east. The currently proposed Project will begin near the Spearville substation in Ford County, Kansas, and end in western Indiana near the Sullivan substation in Sullivan County, Indiana. The estimated length of the transmission line is roughly 700 miles. Clean Line has retained the services of The Louis Berger Group, Inc. (Berger) to conduct a siting study for the proposed Project. The Project is in a relatively early planning phase, and potential routes are still in development. Project development and environmental permitting will be a multi-year process, and Clean Line anticipates the need to obtain federal, state, and local permits from the appropriate agencies. Attached are a list of counties within the study area and an overview map. We respectfully would like to request a meeting with you to introduce the Project and give you an opportunity to comment and provide input. A member of the Berger staff will contact you soon to schedule a meeting and provide an overview of the proposed Project scope and schedule. If you require further information or have questions regarding this matter, please feel free to contact Todd McCabe at mmccabe@louisberger.com or We look forward to working with you throughout the route development and permitting process. For general project information, please visit the project website at or

285 Sincerely, Jason Thomas Director, Environment Clean Line Energy Partners cell tel Attachments: 1. Project Overview Map Cc: Mark Lawlor, Clean Line Energy Partners Diana Coggin, Clean Line Energy Partners Joyce Collins, U.S. Fish and Wildlife Service Todd McCabe, The Louis Berger Group

286 Illinois Counties within the Study Area Adams Christian Clark Clay Clinton Crawford Cumberland Jasper Jefferson Lawrence Marion Monroe Montgomery Morgan Pike Randolph Richland Sangamon Scott Shelby St. Clair Washington Wayne

287 Grain Belt Express Clean Line Illinois Route Selection Study APPENDIX E: PUBLIC INVOLVEMENT MATERIALS

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289 ILLLINOIS ROUNDTABLE INVITEE LETTERS

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291 Community Leader Roundtable Meetings in Illinois Quincy Friday, March 9, :00 a.m. 9:30 a.m. Oakley-Lindsay Center - Lindsay Room 300 Civic Center Plaza Pittsfield Friday, March 9, :00 p.m. 1:30 p.m. Pittsfield Community Center 224 West Washington Street Due to the Grain Belt Express Clean Line s large study area, we are not able to host a meeting in every county. We very much appreciate your attendance and apologize for any inconvenience this may cause. We hope that you will join us at the meeting location nearest you. P.S. Don t forget to RSVP by Monday, February 27 via RSVP@GrainBeltExpressCleanLine.com Toll Free Phone: (855) Please specify which roundtable you will attend.

292 Community Leader Roundtable Meetings in Illinois Jacksonville Monday, April 23, :00 p.m. 3:30 p.m. 110 North East Meeting Room 110 North East Springfield Tuesday, April 24, :00 a.m. 9:30 a.m. Inn at South Second Street Taylorville Tuesday, April 24, :00 p.m. 1:30 p.m. Krieger s Restaurant Banquet Room 105 West Bidwell Street Shelbyville Tuesday, April 24, :00 p.m. 7:30 p.m. Shelbyville Senior Center 325 East North 9th Street Newton Wednesday, April 25, :00 a.m. 9:30 a.m. Parklanes Restaurant 504 East Jourdan Street Toledo Wednesday, April 25, :00 p.m. 1:30 p.m. First Neighbor Bank Corporate Office 109 South New York Street Marshall Wednesday, April 25, :00 p.m. 4:30 p.m. Clark County University of Illinois Extension N. State Highway 1 Robinson Thursday, April 26, :00 a.m. 9:30 a.m. Robinson Community Center 300 South Lincoln Street Olney Thursday, April 26, :00 p.m. 1:30 p.m. The Holiday Boardroom 1300 South West Street Flora Thursday, April 26, :00 p.m. 5:30 p.m. Anthony s Restaurant 107 East North Avenue Mount Vernon Friday, April 27, :00 a.m. 9:30 a.m. Fairfield Inn Meeting Room 217 Potomac Boulevard Red Bud Friday, April 27, :30 p.m. 2:00 p.m. The Office Bar and Grill 123 South Main Street Due to the Grain Belt Express Clean Line s large study area, we are not able to host a meeting in every county. We very much appreciate your attendance and apologize for any inconvenience this may cause. We hope that you will join us at the meeting location nearest you. P.S. Don t forget to RSVP by Monday, April 16 via RSVP@GrainBeltExpressCleanLine.com Toll Free Phone: (855) Please specify which roundtable you will attend.

293 Roundtable Workshop Feedback Name: Organization: Title: Phone: Address: City and Date of Roundtable 1. Are there any concepts or issues that we should address or explain in more detail? 2. Are there any additional key community leaders we should reach out to prior to the open houses? 3. General remarks/comments: Yes, I would like to receive the Grain Belt Express Clean Line newsletter and periodic updates about the project.

294 Roundtable Workshop Feedback. Please fold, fasten, stamp and mail No envelope necessary Place stamp here Grain Belt Express Clean Line c/o Clean Line Energy Partners 1001 McKinney, Suite 700 Houston, TX 77002

295 ILLINOIS PUBLIC MEETING INVITEE LETTERS

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297 November 14, 2014 <Name> <Address 1> <Address 2> <City>, <State> <ZIP> Grain Belt Express Clean Line Dear <Name>, I am writing to inform you about an important energy project being developed in your area, an overhead, electric transmission line called the Grain Belt Express Clean Line ( Grain Belt Express ). You are receiving this invitation because, according to county records, you own property along or near a potential route for the Grain Belt Express. Project Overview Grain Belt Express Clean Line LLC ( Clean Line ) is developing the Grain Belt Express, an approximately 750-mile overhead, direct current transmission line that will deliver low-cost wind power from western Kansas to Illinois and surrounding states. The project will benefit Illinois by adding a new source of cost-competitive renewable energy, reducing wholesale electricity prices, creating hundreds of construction and manufacturing jobs, and providing tax revenue to local communities. Clean Line will apply for a Certificate of Public Convenience and Necessity from the Illinois Commerce Commission ( ICC ) in order to construct and operate the transmission line in Illinois. Public Meetings Clean Line is currently evaluating a number of potential routes for the Grain Belt Express transmission line. Landowners along or near each potential route for the Grain Belt Express are being mailed this invitation to the upcoming public meetings. The purpose of the public meetings is to share information about the Grain Belt Express transmission line and ask for comments on the project and feedback from

298 landowners and community members on routing. Detailed maps of the potential routes will be available at the public meetings. Following the public meetings, the number of potential routes will be reduced based on feedback received during the public meetings and other sources of information. Ultimately, the Grain Belt Express transmission line will be built on the single route approved by the ICC. The schedule for public meetings is enclosed in this mailing. The public meetings will be held in an open house format and no formal presentation will be made, so please come at any time between the listed start and end times. Each public meeting will provide the same information about the project. For more information about the routing process and answers to frequently asked questions, please visit our project website at Clean Line representatives are available to answer questions about the project. Please visit or call 1 (855) Sincerely, Mark Lawlor Director of Development Attachments A. Potential Routes Overview Map B. Public Meeting Information

299 Potential Routes Overview Map Potential routes for the Grain Belt Express are represented on the overview map below. Detailed maps of the potential routes will be available at the public meetings. For more information about the routing process and answers to frequently asked questions, please visit the project website at The purpose of the public meetings is to share information about the Grain Belt Express transmission line and ask for comments on the project and feedback from landowners and community members on routing. Following the public meetings, the number of potential routes will be reduced based on feedback received during the public meetings and other sources of information. This map shows potential routes currently being evaluated. Ultimately, the Grain Belt Express transmission line will be built on the single route approved by the ICC.

300 Public Meeting Information The public meetings will be held in an open house format and no formal presentation will be made, so please come at any time between the listed start and end times. Please note that some of the public meetings will take place in the morning. Martinsville (Clark County) Pana (Christian County) Monday, December 1, 2014 Wednesday, December 3, a.m. to 10 a.m. 5 p.m. to 8 p.m. Martinsville Community Center Fraternal Order of Eagles # West Cumberland Street 186 U.S. Highway 51 Martinsville, IL Pana, IL Greenup (Cumberland County) Monday, December 1, p.m. to 8 p.m. Greenup Municipal Building 115 East Cumberland Street Greenup, IL Shelbyville (Shelby County) Tuesday, December 2, a.m. to 10 a.m. First Church of the Nazarene Christian Life Center 416 North Will Street Shelbyville, IL Hillsboro (Montgomery County) Tuesday, December 2, p.m. to 8 p.m. Moose Lodge 411 South Main Street Hillsboro, IL Carlinville (Macoupin County) Wednesday, December 3, a.m. to 10 a.m. Lake Williamson Christian Center Activity Center Room Lakeside Drive Carlinville, IL Winchester (Scott County) Thursday, December 4, a.m. to 10 a.m. Nimrod Funk Building Scott County Fairground 401 North Walnut Street Winchester, IL Carrollton (Greene County) Thursday, December 4, p.m. to 8 p.m. Carrollton Knights of Columbus Hall 1 Mile South of Carrollton U.S. Highway 67 Carrollton, IL Pittsfield (Pike County) Friday, December 5, a.m. to 10 a.m. American Legion Post West Washington Street Pittsfield, IL 62363

301 January 20, 2015 [Landowner name and address] Re: Notice of Second Round of Public Meetings for the Grain Belt Express Clean Line transmission line project Dear [Landowner], I am writing to update you with further information about an important energy project being developed in your area, an electric transmission line called the Grain Belt Express Clean Line ( Grain Belt Express or the Project ). You are receiving this letter because, according to county records, you own property along or near a potential route for the Grain Belt Express. Project Overview Grain Belt Express Clean Line LLC ( Clean Line ) is developing the Grain Belt Express, an approximately 750-mile overhead, direct current transmission line that will deliver low-cost wind power from western Kansas to Illinois and surrounding states. The Grain Belt Express is designed to benefit Illinois energy consumers. The Project will add a new source of cost-competitive renewable energy, reduce wholesale electricity prices, create hundreds of construction and manufacturing jobs, and provide revenue to local communities in the state. Clean Line will apply for a Certificate of Public Convenience and Necessity from the Illinois Commerce Commission ( ICC ) in order to construct and operate the transmission line in Illinois. Public Meetings Clean Line is currently evaluating a number of potential routes for the Grain Belt Express. The first round of public meetings to discuss the potential routes was held in December A

302 number of potential routes have been revised or eliminated taking into account feedback received at those meetings. Landowners along or near the potential routes currently under evaluation are being mailed this invitation to the upcoming second round of public meetings. The purpose of the upcoming second round of public meetings is to share information about the Grain Belt Express and ask for comments and feedback from landowners and community members on the Project. On Wednesday, Jan. 28, 2015, detailed maps depicting the potential routes currently under evaluation will be available on the Project website, The detailed maps depicting these potential routes will also be available at the upcoming public meetings. Although the maps show a number of potential routes, the Project will ultimately only require one foot wide right-of-way, approved by the ICC. The schedule for the upcoming public meetings is enclosed in this mailing. The public meetings will be held in an open house format and no formal presentation will be made, so please come at any time between the listed start and end times. Each public meeting will provide the same information about the Project. For more information about the routing process and answers to frequently asked questions, please visit the Project website at Sincerely Mark Lawlor Director of Development Enclosures: 1) Overview Map of Potential Routes, 2) Public Meeting Information for Second Round of Public Meetings, and 3) Project Overview

303 January 20, 2015 [Landowner name and address] Re: Updated Notice of Second Round of Public Meetings for the Grain Belt Express Clean Line transmission line project Dear [Landowner], I am writing to update you with further information about the Grain Belt Express Clean Line ( Grain Belt Express or the Project ). You are receiving this letter because, according to county records, you own property along or near a potential route for the Grain Belt Express. This additional notice is to inform you of a potential route segment not included in the overview map in our last notice to you. The enclosed updated overview map is intended to provide a high-level view of the potential route network. The as well as the complete map set with aerial imagery can be viewed on our website, and at the upcoming public meetings detailed below. The routing process requires Clean Line to thoroughly review a number of potential routing options and to revise potential routes as we receive additional information. We encourage you to attend one of the upcoming public meetings where we will have additional project information and maps available. The purpose of the upcoming second round of public meetings is to share information about the Grain Belt Express and ask for comments and feedback from landowners and community members on the Project. Project Overview

304 Grain Belt Express Clean Line LLC ( Clean Line ) is developing the Grain Belt Express, an approximately 750-mile overhead, direct current transmission line that will deliver low-cost wind power from western Kansas to Illinois and surrounding states. The Grain Belt Express is designed to benefit Illinois energy consumers. The Project will add a new source of cost-competitive renewable energy, reduce wholesale electricity prices, create hundreds of construction and manufacturing jobs, and provide revenue to local communities in the state. Clean Line will apply for a Certificate of Public Convenience and Necessity from the Illinois Commerce Commission ( ICC ) in order to construct and operate the transmission line in Illinois. Public Meetings Clean Line is currently evaluating a number of potential routes for the Grain Belt Express. The first round of public meetings to discuss the potential routes was held in December A number of potential routes have been revised or eliminated taking into account feedback received at those meetings. Landowners along or near the potential routes currently under evaluation are being mailed this invitation to the upcoming second round of public meetings. The purpose of the upcoming second round of public meetings is to share information about the Grain Belt Express and ask for comments and feedback from landowners and community members on the Project. On Wednesday, Jan. 28, 2015, detailed maps depicting the potential routes currently under evaluation will be available on the Project website, The detailed maps depicting these potential routes will also be available at the upcoming public meetings. Although the maps show a number of potential routes, the Project will ultimately only require one foot wide right-of-way, approved by the ICC.

305 The schedule for the upcoming public meetings is enclosed in this mailing. The public meetings will be held in an open house format and no formal presentation will be made, so please come at any time between the listed start and end times. Each public meeting will provide the same information about the Project. For more information about the routing process and answers to frequently asked questions, please visit the Project website at Sincerely Mark Lawlor Director of Development Enclosures: 1) Overview Map of Potential Routes, 2) Public Meeting Information for Second Round of Public Meetings

306 Overview Map of Potential Routes The below map is meant to provide an overview of the potential routes currently under evaluation. The first round of public meetings was held in December A number of the potential routes have been revised or eliminated taking into account feedback received at those meetings. On Wednesday, Jan. 28, 2015, detailed maps of the potential routes currently under evaluation will be available on the Project website, The detailed maps depicting these potential routes will also be available at the upcoming public meetings. Although the maps show a number of potential routes, the Project will ultimately only require one foot wide right-of-way, approved by the ICC.