Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
December 14, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
RE: CP12-72, additional information regarding flaws in the historic study/Section 106 review
Dear Secretary Bose,
Myersville Citizens for a Rural Community, Inc. (MCRC) wants to submit additional information that will clarify the issues about
the flaw in the TRC historic study, and therefore the Section 106 review.
According to the Section 106 review, § 800.5 (a) (1), “An adverse effect is found when an undertaking may alter, directly or
indirectly, any of the characteristics of a historic property that qualify the property for inclusion in the National Register in a
manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling, or
association. Consideration shall be given to all qualifying characteristics of a historic property, including those that may have been
identified subsequent to the original evaluation of the property's eligibility for the National Register. Adverse effects may include
reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be
cumulative.”
The emissions of the proposed gas compressor station in Myersville, MD, have direct impact on the material and structure of
historic and archeological buildings and sites. For example, limestone (calcium carbonate), which is a material that is often
encountered in historic and archeological buildings and sites, reacts with acid and is dissolved, in a reaction of 2H+ + CaCO3 ->
H+ + Ca2+ HCO3- -> Ca2+ + H2CO3; H2CO3 can decompose to form H2O (water) and CO2 (carbon dioxide). The acid can
penetrate microscopic cracks and dissolve the material there, leading to larger cracks, which eventually will weaken the structure
of the archeological/historic material. That is the reason why worldwide governments spend a huge amount to restore and rebuild
structures that were damaged by acid rain (for an overview of the potential of the acid to damage building materials, see
http://webarchive.iiasa.ac.at/Admin/PUB/ Documents/WP-89-104.pdf). In addition, acid rain can harm structures containing
iron, copper, and concrete. This is the reason why the EPA, which is more concerned about the environmental impact than
historic impact, released the statement that “Acid rain … causes deterioration …, and historical monuments” in their report,
whereby “historic monument” would include buildings and other structures. In addition, Particulate Matters (PM, 5,500 lbs per
year), can stain and damage stone and other material, including culturally important objects such as statues and monuments areas
as noted by the EPA in http://www.epa.gov/air/particlepollution/health.html. Therefore, it has to be concluded that there is
significant “reasonably foreseeable effects” considering “all qualifying characteristics” of the historic buildings (staining, damage
and deterioration by acid rain and PM) and the Tuner’s and Fox’s Gaps Historic District, NR (reduced visibility, impaired view
shed), even though they are indirectly caused by the proposed gas compressor station.
Another significant effect by the proposed gas compressor station in Myersville, MD, would be due to the location of the
proposed station. The gas compressor station would be located on a downward slope of a V-shaped valley and the historic Fox’s
and Turner’s Gap (F-4-017 BC, National Register), part of the South Mountain Battlefield, would be on the opposite side of this
V-shaped valley. The picture below was taken at the approximate same level where the gas compressor station would be located
(since it would be located on a currently privately owned land we were not able to access the exact same place). In red, part of the
South Mountain Battlefield is visible. We acknowledge that there are trees in this area, but the trees “hiding” the gas compressor
station from the Battlefield area are located downward of the station area. In addition, the building would be 44 ft tall, with the
exhaust stacks being even taller, 68.8 ft (FERC acc# 20120217-5191), which would very likely exceed significantly the height of
the trees downward of the station. Since the Battlefield area is elevated compared to the site of the proposed gas compressor
station, it would be visible from the historic South Mountain Battlefield area. Interestingly, the view analysis study was performed
for all other parts of the Allegheny Storage project, except for Myersville, in DTI’s EA draft and FERC’s EA.
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Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
In comparison the view shed of the site in Middletown, where there were great concerns about the impact of a gas compressor at
that location, would be significantly less impacted (see the pictures below which are showing the view shed from the Middletown
site; Google Maps, 4x 90˚views). The question is why are there not any concerns about the site in Myersville?
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Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
Another significant impact on the view by the proposed gas compressor would be caused by the emissions. The historic report,
which was written by TRC for DTI, does not take into account that Particulate Matter is the major cause of reduced visibility
(haze) in parts of the United States, including many of our treasured parks and wilderness areas, as noted by the EPA in
http://www.epa.gov/air/particlepollution/health.html. Tuner’s and Fox’s Gaps Historic District, NR, is only 0.4 mile from the
site of the proposed gas compressor station in Myersville. It will in fact have a visual impact to this national historic given the gas
compressor station will emit approximately 5,500 lbs of Particulate Matters per year. Especially during inversion events, when
colder air is trapped below warmer air in between the South Mountain and Braddock Mountain, the visual impact / decrease of
visibility will be even more present.
In a correspondence by the MHT, it is discussed that the location near Middletown would likely have had adverse effects on
multiple historic properties, whereas that in Myersville the proposed compressor station and associated pipelines and access roads
would have no effect on historic and archeological resources. By comparison of historic properties listed in the National Register
of Historic Properties, which were the only ones analyzed by TRC’s historic impact study for Myersville, we do not see any
difference between the two sites:
Middletown
Myersville
Name
Designation Distance
Name
Designation Distance
Fox's and Turner's Gap
F-4-017 BC
0.40
Fox's and Turner's Gap
F-4-017 BC
0.40
Henry Shoemaker Farmhouse
F-4-016
1.25
Routzahn-Miller Farmstead F-4-141
1.50
Bowlus Mill House
F-4-101
2.00
Daniel Sheffer Farmstead
F-4-035
1.75
One major concern by the MHT regarding the Middletown site seems to be the proximity to Fox’s Tavern. But this property is
not listed in the National Register of Historic Properties (NR) and would not have been listed in a historic impact study
performed the same way as in Myersville, since TRC’s analysis included only properties listed in the NR, unless Fox’s Tavern is
being considered as being more significant / in a higher classification than other properties, which we are not aware of. If the
analysis is expanded to other historic properties, there are even more properties in about the same distance to the proposed sites
in Myersville than in Middletown. Therefore we are still puzzled by your statement that there would have been adverse effects by
the Middletown site and not by the Myersville site. Please see below the historic properties listed in the Maryland Inventory of
Historic Properties besides those listed in the NR, which are located within 2 miles of the two potential sites, the area of impact
defined by the TRC study for Myersville.
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Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
Middletown
Name
Designation Distance
Beachley Farm
F-4-133
1.50
Beachley House
F-4-029
2.00
Bolivar Survey District
F-4-037
1.10
Fox's Tavern
F-4-028
0.10
Hoffman Farm
F-4-132
1.75
J. Hanson Shafer Farmstead
F-4-090
1.25
John Kepler Farmstead
F-4-027
1.25
Jonas Sheffer Farm
F-4-122
1.50
Kepler Farm
F-4-124
1.50
Old Hagerstown Road Bridge
F-4-002
2.00
Old National Pike
F-4-123
1.00
Old National Pike Milestone No. 54 F-4-075
1.75
Old National Pike Milestone No. 56 F-4-076
1.00
Old Sharpsburg Road
F-4-131
1.00
Ridge Road
F-4-127
1.75
Smith-Remsburg Farmstead
F-4-089
0.75
Spoolsville Survey District
F-4-044
1.75
Stone Wall along the Ridge Road F-4-134
2.00
US 40A Catoctin Creek Bridge
F-4-026
1.75
Myersville
Name
Designation
Beachley-Haupt House
F-4-097
Bridge 10030 (SHA)
F-4-115
Bridge 10031 (SHA)
F-4-116
Bridge 10176
F-4-041
Bridge 10177 (SHA)
F-4-112
Dahlgren Road
F-4-126
Daniel Sheffer Farmstead
F-4-093
Doub-Routzahn Farmstead F-4-079
Ellerton Road Bridge
F-4-006
Enos Doub Farmstead
F-4-031
Frostown Road
F-4-125
Grossnickle Farm
F-4-108
Grossnickle Tenant Farm
F-4-109
Harmony Road Bridge 16-24 F-4-040
Harmony Survey District
F-4-052
Haupt Farm
F-4-118
Hollow Road Bridge
F-4-007
J. O'Neil Farm
F-4-121
Joseph Gaber (Gaver) Farm F-4-119
Mount Tabor Station Bridge F-4-003
Myersville Survey District
F-4-053
Old Harmony Road Bridge
F-4-024
Peter Leatherman Farmstead F-4-032
Philip Derr Farmstead
F-4-091
Pleasant Hill
F-4-012
Schlosser-Waters Farmstead
(Pilgrim's Harbour)
F-4-070
Shank-Ridgely House
F-4-098
Smith-Bowlus House
F-4-046
Distance
1.75
1.25
1.25
0.50
2.00
1.75
1.50
2.00
2.00
1.50
1.50
2.00
1.75
2.00
2.00
1.90
2.00
2.00
1.75
1.75
0.40
2.00
2.00
1.75
0.30
2.00
2.00
0.75
In the TRC report a structure on the Myersville site was found, but valued as not significant. On the Middletown site it seems like
a possible archeological site was found on or close to the property. But any further analysis is lacking, so it is not known if it is of
any significance and therefore it cannot be concluded that it is important without any further analysis. Despite our FOIA request
we were not granted access to further information about archeological sites in the area of impact in Myersville or Middletown, so
we are not able to discuss any further comparison regarding archeological sites around either potential gas compressor site.
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Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
In discussions about the proposed Myersville gas compressor station it is discussed that the site is surrounded by industrial and
commercial areas and a sewer plant. We have gotten the feeling that because of these properties, DTI and FERC as stated in the
EA have the impression that another industrial building would not have much impact anyway, especially regarding the view shed.
Please note that the industrial site you are referring to is actually considered only a light industrial site, with Alban using the area
for mostly storing equipment and a building for repairing equipment. This site does not emit significant amount of emissions
(only from moving equipment), in contrast to dozens of tons of emissions by the proposed gas compressor station which can
deteriorate historic and archeological material in the surrounding area, as mentioned above. In addition, noise comes only from
running the equipment, and there are no blow-downs like from the proposed gas compressor station, that can reach close to 100
dB. The commercial area consists of a bank and some offices in one building, again, no emission or noise except like from normal
heating and car traffic. The sewer plant is located below the site of the proposed gas compressor station. It is shielded well from
the view from South Mountain since it is only a small sewer plant serving less than 2,000 people, it is surrounded by vegetation, it
is small, it is on the bottom of the V-shaped valley and it is shielded by a shoulder /small hill. In contrast, the proposed gas
compressor station would be a large, heavy industrial complex with significant emissions and which is hard/impossible to shield
from the view from South Mountain due to its location and size.
Light Industrial Area: Alban
Commercial Area: Bank – Subway/Doctor’s Office/ Insurance Office/Office of Electrician
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Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
Sewer Plant from entrance from
Milt Summers Rd
Sewer Plant from hill on Mill Summers Rd
that is blocking the plant from South Mountain
Chambersburg
Station,
upstream
Leesburg
Station,
downstream
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Myersville Citizens for a Rural Community
PO Box 158, Myersville, MD 21773
www.mcrcmd.org
In light of the additional information about the inaccuracy and flaws of the historic impact study submitted by TRC for DTI and
the new information provided in this letter, we ask FERC to dismiss the historic impact study that is grounds for the MHT
Section 106 review and FERC’s EA.
We appreciate your time and consideration of our information. Sincerely,
Franz Gerner, Ph.D
President – Myersville Citizens for a Rural Community, Inc.
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