A transmission line model describing the electrochemical impedance spectroscopy (EIS) behavior of the EMD electrode in concentrated KOH electrolytes has been developed. The model takes into consideration the various charge transport paths through the electrode. In general, it consists of parameters describing the electrical, electrochemical and geometric properties of the electrode. Arbitrary values were selected for these parameters and used to calculate the electrode impedance as a function of frequency. The trends in the calculated data were consistent with our physical picture of the electrode. Experimental EIS data from a previous study was modeled using the transmission line. The comparison between experimental and predicted data was excellent (< 3% deviation).