No transmission line of this length, voltage or capacity has ever been placed underground, nor has the technology been commercially developed at this voltage level. Even if the technology was available, the project cost would increase dramatically – as much as 10 to 20 times or more – and the time to complete the project would increase substantially. Prolonged outages are required to repair underground cable failures, and this could jeopardize the reliability of our power system. The environmental impact of undergrounding is significant – underground cables require massive excavation that could severely impact streams, wetlands and other sensitive areas. Multiple above-ground stations would be required along the line route, with permanent access required along the full length of the line for maintenance and repairs. Transmission is typically placed underground for relatively short distances, and only when an overhead option is not feasible. AEP and Allegheny have and will continue to p